SECURITIES INDUSTRY AND FINANCIAL MARKETS ASSOCIATION INC: Form 990, tax year 2020
View the entire original 990 at ProPublica ↗
- Organization
- SECURITIES INDUSTRY AND FINANCIAL MARKETS ASSOCIATION INC (EIN 32-0178959)
- Tax period
- 2020-11-01 to 2021-10-31
- Filed
- 2022-08-24
- IRS object ID
- 202242369349301564
- Schema version
- 2020v4.2
- Source
- Download XML · Original 990 at ProPublica
Every field in the e-filed return. Faint text is the IRS element name, for citing.
Return header ReturnHeader
| Field | Value | IRS element (for citing) |
|---|---|---|
| Return | 2022-08-24T15:27:44-05:00 | ReturnTs |
| Tax Period End | 2021-10-31 | TaxPeriodEndDt |
Preparer Firm PreparerFirmGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Preparer Firm EIN | 366055558 | PreparerFirmEIN |
Preparer Firm Name PreparerFirmName
| Field | Value | IRS element (for citing) |
|---|---|---|
| Business Name Line1 | GRANT THORNTON LLP | BusinessNameLine1Txt |
Preparer US Address PreparerUSAddress
| Field | Value | IRS element (for citing) |
|---|---|---|
| Address Line1 | 757 THIRD AVENUE 3RD FLOOR | AddressLine1Txt |
| City | NEW YORK | CityNm |
| State Abbreviation | NY | StateAbbreviationCd |
| ZIP | 100172013 | ZIPCd |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Return Type | 990 | ReturnTypeCd |
| Tax Period Begin | 2020-11-01 | TaxPeriodBeginDt |
Filer Filer
| Field | Value | IRS element (for citing) |
|---|---|---|
| EIN | 320178959 | EIN |
Business Name BusinessName
| Field | Value | IRS element (for citing) |
|---|---|---|
| Business Name Line1 | SECURITIES INDUSTRY AND FINANCIAL | BusinessNameLine1Txt |
| Business Name Line2 | MARKETS ASSOCIATION | BusinessNameLine2Txt |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Business Name Control | SECU | BusinessNameControlTxt |
| Phone | 2123131371 | PhoneNum |
US Address USAddress
| Field | Value | IRS element (for citing) |
|---|---|---|
| Address Line1 | 140 BROADWAY 35TH FLOOR | AddressLine1Txt |
| City | NEW YORK | CityNm |
| State Abbreviation | NY | StateAbbreviationCd |
| ZIP | 10005 | ZIPCd |
Business Officer BusinessOfficerGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Person | DAVID KRASNER | PersonNm |
| Person Title | CFO & CAO | PersonTitleTxt |
| Phone | 2123131371 | PhoneNum |
| Signature | 2022-08-24 | SignatureDt |
| Discuss With Paid Preparer | Yes (1) | DiscussWithPaidPreparerInd |
Signing Officer SigningOfficerGrp
Person Full Name PersonFullName
| Field | Value | IRS element (for citing) |
|---|---|---|
| Person First | DAVID | PersonFirstNm |
| Person Last | KRASNER | PersonLastNm |
| Field | Value | IRS element (for citing) |
|---|---|---|
| SSN | XXX-XX-XXXX | SSN |
Preparer Person PreparerPersonGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Preparer Person | DANIEL ROMANO | PreparerPersonNm |
| PTIN | P00504182 | PTIN |
| Phone | 2125990100 | PhoneNum |
Additional Filer Information AdditionalFilerInformation
Trusted Customer TrustedCustomerGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Trusted Customer | 3 | TrustedCustomerCd |
| Authentication Assurance Level | AAL1 | AuthenticationAssuranceLevelCd |
| Identity Assurance Level | IAL1 | IdentityAssuranceLevelCd |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Tax | 2020 | TaxYr |
| Build TS | 2022-09-23 18:48:47Z | BuildTS |
Form 990 IRS990
| Field | Value | IRS element (for citing) |
|---|---|---|
| Address Change | Yes (X) | AddressChangeInd |
| Principal Officer | KENNETH E BENTSEN JR | PrincipalOfficerNm |
US Address USAddress
| Field | Value | IRS element (for citing) |
|---|---|---|
| Address Line1 | 140 BROADWAY 35TH FLOOR | AddressLine1Txt |
| City | NEW YORK | CityNm |
| State Abbreviation | NY | StateAbbreviationCd |
| ZIP | 10005 | ZIPCd |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Gross Receipts | $47,657,181 | GrossReceiptsAmt |
| Group Return For Affiliates | 0 | GroupReturnForAffiliatesInd |
| Organization501c | Yes (X) | Organization501cInd |
| Website Address | WWW.SIFMA.ORG | WebsiteAddressTxt |
| Type Of Organization Corp | Yes (X) | TypeOfOrganizationCorpInd |
| Formation | 2006 | FormationYr |
| Legal Domicile State | DE | LegalDomicileStateCd |
| Activity Or Mission | SIFMA IS THE LEADING TRADE ASSOCIATION FOR BROKER-DEALERS, INVESTMENT BANKS (CONT. ON SCH. O) | ActivityOrMissionDesc |
| Voting Members Governing Body | 41 | VotingMembersGoverningBodyCnt |
| Voting Members Independent | 40 | VotingMembersIndependentCnt |
| Total Employee | 136 | TotalEmployeeCnt |
| Total Volunteers | 16574 | TotalVolunteersCnt |
| Total Gross UBI | $206,418 | TotalGrossUBIAmt |
| Net Unrelated Bus Txbl Incm | $107,483 | NetUnrelatedBusTxblIncmAmt |
| PY Contributions Grants | $0 | PYContributionsGrantsAmt |
| CY Contributions Grants | $0 | CYContributionsGrantsAmt |
| PY Program Service Revenue | $44,084,483 | PYProgramServiceRevenueAmt |
| CY Program Service Revenue | $46,783,222 | CYProgramServiceRevenueAmt |
| PY Investment Income | $597,572 | PYInvestmentIncomeAmt |
| CY Investment Income | $215,742 | CYInvestmentIncomeAmt |
| PY Other Revenue | $716,844 | PYOtherRevenueAmt |
| CY Other Revenue | $658,217 | CYOtherRevenueAmt |
| PY Total Revenue | $45,398,899 | PYTotalRevenueAmt |
| CY Total Revenue | $47,657,181 | CYTotalRevenueAmt |
| PY Grants And Similar Paid | $167,248 | PYGrantsAndSimilarPaidAmt |
| CY Grants And Similar Paid | $193,519 | CYGrantsAndSimilarPaidAmt |
| PY Benefits Paid To Members | $0 | PYBenefitsPaidToMembersAmt |
| CY Benefits Paid To Members | $0 | CYBenefitsPaidToMembersAmt |
| PY Salaries Comp Emp Bnft Paid | $34,231,574 | PYSalariesCompEmpBnftPaidAmt |
| CY Salaries Comp Emp Bnft Paid | $34,688,229 | CYSalariesCompEmpBnftPaidAmt |
| PY Total Prof Fndrsng Expns | $0 | PYTotalProfFndrsngExpnsAmt |
| CY Total Prof Fndrsng Expns | $0 | CYTotalProfFndrsngExpnsAmt |
| CY Total Fundraising Expense | $0 | CYTotalFundraisingExpenseAmt |
| PY Other Expenses | $15,929,592 | PYOtherExpensesAmt |
| CY Other Expenses | $14,408,725 | CYOtherExpensesAmt |
| PY Total Expenses | $50,328,414 | PYTotalExpensesAmt |
| CY Total Expenses | $49,290,473 | CYTotalExpensesAmt |
| PY Revenues Less Expenses | -$4,929,515 | PYRevenuesLessExpensesAmt |
| CY Revenues Less Expenses | -$1,633,292 | CYRevenuesLessExpensesAmt |
| Total Assets BOY | $44,078,460 | TotalAssetsBOYAmt |
| Total Assets EOY | $42,827,387 | TotalAssetsEOYAmt |
| Total Liabilities BOY | $25,514,963 | TotalLiabilitiesBOYAmt |
| Total Liabilities EOY | $24,933,317 | TotalLiabilitiesEOYAmt |
| Net Assets Or Fund Balances BOY | $18,563,497 | NetAssetsOrFundBalancesBOYAmt |
| Net Assets Or Fund Balances EOY | $17,894,070 | NetAssetsOrFundBalancesEOYAmt |
| Info In Schedule O Part III | Yes (X) | InfoInScheduleOPartIIIInd |
| Mission | SEE SCHEDULE OSIFMA IS THE LEADING TRADE ASSOCIATION FOR BROKER-DEALERS, INVESTMENT BANKS AND ASSET MANAGERS OPERATING IN THE U.S. AND GLOBAL CAPITAL MARKETS. ON BEHALF OF OUR INDUSTRY'S NEARLY 1 MILLION EMPLOYEES, WE ADVOCATE ON LEGISLATION, REGULATION AND BUSINESS POLICY, AFFECTING RETAIL AND INSTITUTIONAL INVESTORS, EQUITY AND FIXED INCOME MARKETS AND RELATED PRODUCTS AND SERVICES. WE SERVE AS AN INDUSTRY COORDINATING BODY TO PROMOTE FAIR AND ORDERLY MARKETS, INFORMED REGULATORY COMPLIANCE, AND EFFICIENT MARKET OPERATIONS AND RESILIENCY. WE ALSO PROVIDE A FORUM FOR INDUSTRY POLICY AND PROFESSIONAL DEVELOPMENT. | MissionDesc |
| Significant New Program Srvc | 0 | SignificantNewProgramSrvcInd |
| Significant Change | 0 | SignificantChangeInd |
| Desc | SEE SCHEDULE O | Desc |
Prog Srvc Accom Acty2 ProgSrvcAccomActy2Grp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Desc | SEE SCHEDULE O | Desc |
Prog Srvc Accom Acty3 ProgSrvcAccomActy3Grp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Desc | SEE SCHEDULE O | Desc |
Prog Srvc Accom Acty Other ProgSrvcAccomActyOtherGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Desc | CONTINUED SERVING AS A SOURCE OF MARKET INFORMATION, INCLUDING STATISTICS ON MANY FACETS OF THE MARKET PLACE AND PUBLISHING RESEARCH REPORTS, TRADE NEWSLETTERS AND OTHER PERIODICALS AND BOOKS. | Desc |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Described In Section501c3 | 0 | DescribedInSection501c3Ind |
| Schedule B Required | 0 | ScheduleBRequiredInd |
| Political Campaign Acty | 0 | PoliticalCampaignActyInd |
| Subject To Proxy Tax | Yes (1) | SubjectToProxyTaxInd |
| Donor Advised Fund | 0 | DonorAdvisedFundInd |
| Conservation Easements | 0 | ConservationEasementsInd |
| Collections Of Art | 0 | CollectionsOfArtInd |
| Credit Counseling | Yes (1) | CreditCounselingInd |
| Donor Rstr Or Quasi Endowments | 0 | DonorRstrOrQuasiEndowmentsInd |
| Report Land Building Equipment | Yes (1) | ReportLandBuildingEquipmentInd |
| Report Investments Other Sec | 0 | ReportInvestmentsOtherSecInd |
| Report Program Related Invst | 0 | ReportProgramRelatedInvstInd |
| Report Other Assets | Yes (1) | ReportOtherAssetsInd |
| Report Other Liabilities | Yes (1) | ReportOtherLiabilitiesInd |
| Include FIN48 Footnote | Yes (1) | IncludeFIN48FootnoteInd |
| Independent Audit Fincl Stmt | Yes (1) | IndependentAuditFinclStmtInd |
| Consolidated Audit Fincl Stmt | 0 | ConsolidatedAuditFinclStmtInd |
| School Operating | 0 | SchoolOperatingInd |
| Foreign Office | 0 | ForeignOfficeInd |
| Foreign Activities | 0 | ForeignActivitiesInd |
| More Than5000 K To Org | 0 | MoreThan5000KToOrgInd |
| More Than5000 K To Individuals | 0 | MoreThan5000KToIndividualsInd |
| Professional Fundraising | 0 | ProfessionalFundraisingInd |
| Fundraising Activities | 0 | FundraisingActivitiesInd |
| Gaming Activities | 0 | GamingActivitiesInd |
| Operate Hospital | 0 | OperateHospitalInd |
| Grants To Organizations | Yes (1) | GrantsToOrganizationsInd |
| Grants To Individuals | 0 | GrantsToIndividualsInd |
| Schedule J Required | Yes (1) | ScheduleJRequiredInd |
| Tax Exempt Bonds | 0 | TaxExemptBondsInd |
| Loan Outstanding | 0 | LoanOutstandingInd |
| Grant To Related Person | 0 | GrantToRelatedPersonInd |
| Business Rln With Org Mem | 0 | BusinessRlnWithOrgMemInd |
| Business Rln With Fam Mem | 0 | BusinessRlnWithFamMemInd |
| Business Rln With35 Ctrl Ent | 0 | BusinessRlnWith35CtrlEntInd |
| Deductible Non Cash Contri | 0 | DeductibleNonCashContriInd |
| Deductible Art Contribution | 0 | DeductibleArtContributionInd |
| Terminate Operations | 0 | TerminateOperationsInd |
| Partial Liquidation | 0 | PartialLiquidationInd |
| Disregarded Entity | 0 | DisregardedEntityInd |
| Related Entity | 0 | RelatedEntityInd |
| Related Organization Ctrl Ent | 0 | RelatedOrganizationCtrlEntInd |
| Activities Conducted Prtshp | 0 | ActivitiesConductedPrtshpInd |
| Schedule O Required | Yes (1) | ScheduleORequiredInd |
| IRP Document | 102 | IRPDocumentCnt |
| IRP Document W2 G | 0 | IRPDocumentW2GCnt |
| Backup Wthld Compliance | Yes (1) | BackupWthldComplianceInd |
| Employee | 136 | EmployeeCnt |
| Employment Tax Returns Filed | Yes (1) | EmploymentTaxReturnsFiledInd |
| Unrelated Bus Incm Over Limit | Yes (1) | UnrelatedBusIncmOverLimitInd |
| Form990 T Filed | Yes (1) | Form990TFiledInd |
| Foreign Financial Account | 0 | ForeignFinancialAccountInd |
| Prohibited Tax Shelter Trans | 0 | ProhibitedTaxShelterTransInd |
| Taxable Party Notification | 0 | TaxablePartyNotificationInd |
| Nondeductible Contributions | 0 | NondeductibleContributionsInd |
| Indoor Tanning Services | 0 | IndoorTanningServicesInd |
| Subj To Tax Rmnrtn Ex Prcht Pymt | Yes (1) | SubjToTaxRmnrtnExPrchtPymtInd |
| Subject To Excs Tax Net Invst Inc | 0 | SubjectToExcsTaxNetInvstIncInd |
| Info In Schedule O Part VI | Yes (X) | InfoInScheduleOPartVIInd |
| Governing Body Voting Members | 41 | GoverningBodyVotingMembersCnt |
| Independent Voting Member | 40 | IndependentVotingMemberCnt |
| Family Or Business Rln | 0 | FamilyOrBusinessRlnInd |
| Delegation Of Mgmt Duties | 0 | DelegationOfMgmtDutiesInd |
| Change To Org Documents | 0 | ChangeToOrgDocumentsInd |
| Material Diversion Or Misuse | 0 | MaterialDiversionOrMisuseInd |
| Members Or Stockholders | Yes (1) | MembersOrStockholdersInd |
| Election Of Board Members | Yes (1) | ElectionOfBoardMembersInd |
| Decisions Subject To Approva | 0 | DecisionsSubjectToApprovaInd |
| Minutes Of Governing Body | Yes (1) | MinutesOfGoverningBodyInd |
| Minutes Of Committees | Yes (1) | MinutesOfCommitteesInd |
| Officer Mailing Address | 0 | OfficerMailingAddressInd |
| Local Chapters | 0 | LocalChaptersInd |
| Form990 Provided To Gvrn Body | Yes (1) | Form990ProvidedToGvrnBodyInd |
| Conflict Of Interest Policy | Yes (1) | ConflictOfInterestPolicyInd |
| Annual Disclosure Covered Prsn | Yes (1) | AnnualDisclosureCoveredPrsnInd |
| Regular Monitoring Enfrc | Yes (1) | RegularMonitoringEnfrcInd |
| Whistleblower Policy | Yes (1) | WhistleblowerPolicyInd |
| Document Retention Policy | Yes (1) | DocumentRetentionPolicyInd |
| Compensation Process CEO | Yes (1) | CompensationProcessCEOInd |
| Compensation Process Other | Yes (1) | CompensationProcessOtherInd |
| Investment In Joint Venture | 0 | InvestmentInJointVentureInd |
| Upon Request | Yes (X) | UponRequestInd |
Books In Care Of Detail BooksInCareOfDetail
Business Name BusinessName
| Field | Value | IRS element (for citing) |
|---|---|---|
| Business Name Line1 | NAM KIM | BusinessNameLine1Txt |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Phone | 2123131371 | PhoneNum |
US Address USAddress
| Field | Value | IRS element (for citing) |
|---|---|---|
| Address Line1 | 140 BROADWAY 35TH FLOOR | AddressLine1Txt |
| City | NEW YORK | CityNm |
| State Abbreviation | NY | StateAbbreviationCd |
| ZIP | 10005 | ZIPCd |
Form990 Part VII Section A Form990PartVIISectionAGrp (52 entries)
| TitleTitleTxt | Average Hours Per WeekAverageHoursPerWeekRt | Average Hours Per Week Rltd OrgAverageHoursPerWeekRltdOrgRt | Individual Trustee Or DirectorIndividualTrusteeOrDirectorInd | OfficerOfficerInd | Reportable Comp From OrgReportableCompFromOrgAmt | Reportable Comp From Rltd OrgReportableCompFromRltdOrgAmt | Other CompensationOtherCompensationAmt | Key EmployeeKeyEmployeeInd | Highest Compensated EmployeeHighestCompensatedEmployeeInd |
|---|---|---|---|---|---|---|---|---|---|
| KENNETH E BENTSEN JR | |||||||||
| PRESIDENT & CEO | 40.00 | 0.00 | Yes (X) | Yes (X) | $2,418,686 | $0 | $71,415 | ||
| JOHN FW ROGERS | |||||||||
| CHAIR | 2.00 | 0.00 | Yes (X) | Yes (X) | $0 | $0 | $0 | ||
| THOMAS PLUTA | |||||||||
| CHAIR ELECT | 2.00 | 0.00 | Yes (X) | Yes (X) | $0 | $0 | $0 | ||
| JIM REYNOLDS | |||||||||
| VICE CHAIR | 2.00 | 0.00 | Yes (X) | Yes (X) | $0 | $0 | $0 | ||
| JAMES WALLIN | |||||||||
| TREASURER | 2.00 | 0.00 | Yes (X) | Yes (X) | $0 | $0 | $0 | ||
| KEVIN BAILEY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| KENNETH CELLA | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| LAURA CHEPUCAVAGE | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| MICHAEL CROWL | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JAMES CROWLEY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| MICHAEL DURBIN | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| MATTHEW ENYEDI | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JOHN ETTELSON | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| MEGAN FLAHERTY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| PAUL GALIETTO | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| GARY HALL | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| ROBERT HAWLEY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| LISA KIDD HUNT | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| FRANCIS KELLY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JIM KERR | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| MICHAEL KISBER | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| ANDREW KOMAROFF | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| RONALD KRUSZEWSKI | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| CHARLOTTE MCLAUGHLIN | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| THOMAS MERCHANT | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| CRAIG MESSINGER | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JOE NADREAU | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| SHELLEY O'CONNOR | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| DOUGLAS PREISER | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JAMIE PRICE | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| SAMUEL RAMIREZ JR | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| BRENDAN REILLY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| PAUL REILLY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JEFFREY ROSEN | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| PETER SCHNEIDER | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| DEB SCHONEMAN | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| MARK STEFFENSEN | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JOSEPH E SWEENEY | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| JOHN TAFT | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| RYAN TAYLOR | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| KASHIF ZAFAR | |||||||||
| DIRECTOR | 1.00 | 0.00 | Yes (X) | $0 | $0 | $0 | |||
| IRA D HAMMERMAN | |||||||||
| EVP/GC (SEE SCH. J 457 FN) | 40.00 | 0.00 | Yes (X) | $982,302 | $0 | $79,692 | |||
| DAVID B KRASNER | |||||||||
| CFO & CAO | 40.00 | 0.00 | Yes (X) | $692,590 | $0 | $81,049 | |||
| JOSEPH SEIDEL | |||||||||
| COO | 40.00 | 0.00 | $1,093,334 | $0 | $77,478 | Yes (X) | |||
| CHERYL L CRISPEN | |||||||||
| EXECUTIVE VICE PRESIDENT | 40.00 | 0.00 | $594,666 | $0 | $38,950 | Yes (X) | |||
| JAMIE WALL | |||||||||
| EXECUTIVE VICE PRESIDENT | 40.00 | 0.00 | $599,544 | $0 | $36,978 | Yes (X) | |||
| SALVATORE CHIARELLI | |||||||||
| EXECUTIVE VICE PRESIDENT | 40.00 | 0.00 | $372,987 | $0 | $67,909 | Yes (X) | |||
| TIMOTHY W CAMERON | |||||||||
| MANAGING DIRECTOR | 40.00 | 0.00 | $627,766 | $0 | $70,529 | Yes (X) | |||
| MARK SCHUERMANN | |||||||||
| MANAGING DIRECTOR | 40.00 | 0.00 | $560,504 | $0 | $52,605 | Yes (X) | |||
| ROBERT TOOMEY | |||||||||
| MANAGING DIRECTOR | 40.00 | 0.00 | $527,302 | $0 | $82,168 | Yes (X) | |||
| VICTORIA CUMINGS | |||||||||
| MANAGING DIRECTOR | 40.00 | 0.00 | $518,698 | $0 | $51,304 | Yes (X) | |||
| CARTER K MCDOWELL | |||||||||
| MANAGING DIRECTOR | 40.00 | 0.00 | $499,574 | $0 | $68,225 | Yes (X) | |||
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Reportable Comp From Org | $9,487,953 | TotalReportableCompFromOrgAmt |
| Tot Reportable Comp Rltd Org | $0 | TotReportableCompRltdOrgAmt |
| Total Other Compensation | $778,302 | TotalOtherCompensationAmt |
| Indiv Rcvd Greater Than100 K | 71 | IndivRcvdGreaterThan100KCnt |
| Former Ofcr Employees Listed | 0 | FormerOfcrEmployeesListedInd |
| Total Comp Greater Than150 K | Yes (1) | TotalCompGreaterThan150KInd |
| Compensation From Other Srcs | 0 | CompensationFromOtherSrcsInd |
Contractor Compensation ContractorCompensationGrp (5 entries)
| Address Line1ContractorAddress/USAddress/AddressLine1Txt | CityContractorAddress/USAddress/CityNm | State AbbreviationContractorAddress/USAddress/StateAbbreviationCd | ZIPContractorAddress/USAddress/ZIPCd | ServicesServicesDesc | CompensationCompensationAmt |
|---|---|---|---|---|---|
| COVINGTON & BURLING LLP | |||||
| ONE CITYCENTER 850 TENTH ST NW | WASHINGTON | DC | 20001 | LEGAL | $955,140 |
| ERNST & YOUNG LLP | |||||
| PO BOX 640382 | PITTSBURGH | PA | 152640382 | CONSULTING | $480,000 |
| HILLTOP PUBLIC SOLUTIONS LLC | |||||
| 3000 K STREET NW SUITE 320 | WASHINGTON | DC | 20007 | CONSULTING | $392,214 |
| GRANT THORNTON LLP | |||||
| 33570 TREASURY CENTER | CHICAGO | IL | 606943500 | ACCOUNTING | $197,070 |
| ELMENDORF RYAN | |||||
| 1201 NEW YORK AVENUE NW SUITE 900 | WASHINGTON | DC | 20005 | CONSULTING | $165,000 |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Cntrct Rcvd Greater Than100 K | 13 | CntrctRcvdGreaterThan100KCnt |
Program Service Revenue ProgramServiceRevenueGrp (3 entries)
| DescDesc | BusinessBusinessCd | Total Revenue ColumnTotalRevenueColumnAmt | Related Or Exempt Func IncomeRelatedOrExemptFuncIncomeAmt | Unrelated Business RevenueUnrelatedBusinessRevenueAmt |
|---|---|---|---|---|
| MEMBER DUES | 541900 | $39,604,053 | $39,604,053 | |
| CONFERENCES | 541900 | $7,029,240 | $7,029,240 | |
| PUBLICATION SALES | 900099 | $149,929 | $146,929 | $3,000 |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Program Service Revenue | $46,783,222 | TotalProgramServiceRevenueAmt |
Investment Income InvestmentIncomeGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Revenue Column | $215,742 | TotalRevenueColumnAmt |
| Exclusion | $215,742 | ExclusionAmt |
Royalties Revenue RoyaltiesRevenueGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Revenue Column | $204,729 | TotalRevenueColumnAmt |
| Unrelated Business Revenue | $203,418 | UnrelatedBusinessRevenueAmt |
| Exclusion | $1,311 | ExclusionAmt |
Other Revenue Misc OtherRevenueMiscGrp (2 entries)
| DescDesc | BusinessBusinessCd | Total Revenue ColumnTotalRevenueColumnAmt | ExclusionExclusionAmt |
|---|---|---|---|
| SHARED SERVICE AGREEMENTS | 561000 | $412,785 | $412,785 |
| MISCELLANEOUS REVENUE | 900099 | $40,703 | $40,703 |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Other Revenue Total | $453,488 | OtherRevenueTotalAmt |
Total Revenue TotalRevenueGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Revenue Column | $47,657,181 | TotalRevenueColumnAmt |
| Related Or Exempt Func Income | $46,780,222 | RelatedOrExemptFuncIncomeAmt |
| Unrelated Business Revenue | $206,418 | UnrelatedBusinessRevenueAmt |
| Exclusion | $670,541 | ExclusionAmt |
Grants To Domestic Orgs GrantsToDomesticOrgsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $193,519 | TotalAmt |
Comp Current Ofcr Directors CompCurrentOfcrDirectorsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $7,181,220 | TotalAmt |
Other Salaries And Wages OtherSalariesAndWagesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $21,984,145 | TotalAmt |
Pension Plan Contributions PensionPlanContributionsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $1,945,594 | TotalAmt |
Other Employee Benefits OtherEmployeeBenefitsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $2,188,660 | TotalAmt |
Payroll Taxes PayrollTaxesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $1,388,610 | TotalAmt |
Fees For Services Management FeesForServicesManagementGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $31,593 | TotalAmt |
Fees For Services Legal FeesForServicesLegalGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $2,410,733 | TotalAmt |
Fees For Services Accounting FeesForServicesAccountingGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $129,603 | TotalAmt |
Fees For Services Lobbying FeesForServicesLobbyingGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $624,300 | TotalAmt |
Fees For Srvc Invst Mgmnt Fees FeesForSrvcInvstMgmntFeesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $7,963 | TotalAmt |
Fees For Services Other FeesForServicesOtherGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $986,427 | TotalAmt |
Office Expenses OfficeExpensesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $515,299 | TotalAmt |
Information Technology InformationTechnologyGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $677,330 | TotalAmt |
Occupancy OccupancyGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $3,788,818 | TotalAmt |
Travel TravelGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $111,742 | TotalAmt |
Conferences Meetings ConferencesMeetingsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $1,800,081 | TotalAmt |
Depreciation Depletion DepreciationDepletionGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $1,953,220 | TotalAmt |
Other Expenses OtherExpensesGrp (4 entries)
| DescDesc | TotalTotalAmt |
|---|---|
| SUBSCRIPTION AND BOOKS | $618,612 |
| UBTI/EXCISE TAX EXPENSE | $328,244 |
| DUES & REGISTRATION | $142,796 |
| BANK CHARGES & CC FEES | $112,832 |
All Other Expenses AllOtherExpensesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $169,132 | TotalAmt |
Total Functional Expenses TotalFunctionalExpensesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total | $49,290,473 | TotalAmt |
Cash Non Interest Bearing CashNonInterestBearingGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $1,299,649 | BOYAmt |
| EOY | $2,859,342 | EOYAmt |
Savings And Temp Cash Invst SavingsAndTempCashInvstGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $18,871,390 | BOYAmt |
| EOY | $16,880,911 | EOYAmt |
Accounts Receivable AccountsReceivableGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $145,796 | BOYAmt |
| EOY | $65,417 | EOYAmt |
Prepaid Expenses Defrd Charges PrepaidExpensesDefrdChargesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $2,245,349 | BOYAmt |
| EOY | $2,500,195 | EOYAmt |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Land Bldg Equip Cost Or Other Bss | $26,188,777 | LandBldgEquipCostOrOtherBssAmt |
| Land Bldg Equip Accum Deprec | $22,169,263 | LandBldgEquipAccumDeprecAmt |
Land Bldg Equip Basis Net LandBldgEquipBasisNetGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $5,428,375 | BOYAmt |
| EOY | $4,019,514 | EOYAmt |
Investments Pub Traded Sec InvestmentsPubTradedSecGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $12,833,306 | BOYAmt |
| EOY | $14,203,814 | EOYAmt |
Other Assets Total OtherAssetsTotalGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $3,254,595 | BOYAmt |
| EOY | $2,298,194 | EOYAmt |
Total Assets TotalAssetsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $44,078,460 | BOYAmt |
| EOY | $42,827,387 | EOYAmt |
Accounts Payable Accr Expnss AccountsPayableAccrExpnssGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $9,220,689 | BOYAmt |
| EOY | $10,143,524 | EOYAmt |
Deferred Revenue DeferredRevenueGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $4,274,138 | BOYAmt |
| EOY | $3,160,888 | EOYAmt |
Escrow Account Liability EscrowAccountLiabilityGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $433,536 | BOYAmt |
| EOY | $276,532 | EOYAmt |
Other Liabilities OtherLiabilitiesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $11,586,600 | BOYAmt |
| EOY | $11,352,373 | EOYAmt |
Total Liabilities TotalLiabilitiesGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $25,514,963 | BOYAmt |
| EOY | $24,933,317 | EOYAmt |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Organization Follows FASB117 | Yes (X) | OrganizationFollowsFASB117Ind |
No Donor Restriction Net Assets NoDonorRestrictionNetAssetsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $18,563,497 | BOYAmt |
| EOY | $17,894,070 | EOYAmt |
Total Net Assets Fund Balance TotalNetAssetsFundBalanceGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $18,563,497 | BOYAmt |
| EOY | $17,894,070 | EOYAmt |
Tot Liab Net Assets Fund Balance TotLiabNetAssetsFundBalanceGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| BOY | $44,078,460 | BOYAmt |
| EOY | $42,827,387 | EOYAmt |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Info In Schedule O Part XI | Yes (X) | InfoInScheduleOPartXIInd |
| Reconcilation Revenue Expnss | -$1,633,292 | ReconcilationRevenueExpnssAmt |
| Net Unrlzd Gains Losses Invst | $1,260,210 | NetUnrlzdGainsLossesInvstAmt |
| Other Changes In Net Assets | -$296,345 | OtherChangesInNetAssetsAmt |
| Method Of Accounting Accrual | Yes (X) | MethodOfAccountingAccrualInd |
| Accountant Compile Or Review | 0 | AccountantCompileOrReviewInd |
| FS Audited | Yes (1) | FSAuditedInd |
FS Audited Basis FSAuditedBasisGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Separate Basis Fincl Stmt | Yes (X) | SeparateBasisFinclStmtInd |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Audit Committee | Yes (1) | AuditCommitteeInd |
| Federal Grant Audit Required | 0 | FederalGrantAuditRequiredInd |
Schedule C IRS990ScheduleC
| Field | Value | IRS element (for citing) |
|---|---|---|
| Substantially All Dues Nonded | 0 | SubstantiallyAllDuesNondedInd |
| Only In House Lobbying | 0 | OnlyInHouseLobbyingInd |
| Agree Carryover Prior Year | Yes (1) | AgreeCarryoverPriorYearInd |
| Dues Assessments | $39,604,053 | DuesAssessmentsAmt |
| Non Deductible Lbbyng Pltcl CY | $6,856,000 | NonDeductibleLbbyngPltclCYAmt |
| Non Ded Lbbyng Pltcl Cyov | $1,468,817 | NonDedLbbyngPltclCyovAmt |
| Non Deductible Lbbyng Pltcl Tot | $8,324,817 | NonDeductibleLbbyngPltclTotAmt |
| Aggregate Reported Dues Ntc | $7,128,730 | AggregateReportedDuesNtcAmt |
| Carried Over | $1,196,087 | CarriedOverAmt |
Schedule D IRS990ScheduleD
| Field | Value | IRS element (for citing) |
|---|---|---|
| Agent Trustee Etc | 0 | AgentTrusteeEtcInd |
| Incl Escrow Custodial Acct Liab | Yes (1) | InclEscrowCustodialAcctLiabInd |
| Explanation Provided | Yes (X) | ExplanationProvidedInd |
Leasehold Improvements LeaseholdImprovementsGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Other Cost Or Other Basis | $19,074,604 | OtherCostOrOtherBasisAmt |
| Depreciation | $16,616,251 | DepreciationAmt |
| Book Value | $2,458,353 | BookValueAmt |
Equipment EquipmentGrp
| Field | Value | IRS element (for citing) |
|---|---|---|
| Other Cost Or Other Basis | $7,114,173 | OtherCostOrOtherBasisAmt |
| Depreciation | $5,553,012 | DepreciationAmt |
| Book Value | $1,561,161 | BookValueAmt |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Book Value Land Buildings | $4,019,514 | TotalBookValueLandBuildingsAmt |
Other Assets Org OtherAssetsOrgGrp (2 entries)
| DescDesc | Book ValueBookValueAmt |
|---|---|
| OTHER LONG-TERM ASSETS | $2,137,029 |
| DUE FROM THIRD PARTIES | $161,165 |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Book Value Other Assets | $2,298,194 | TotalBookValueOtherAssetsAmt |
Other Liabilities Org OtherLiabilitiesOrgGrp (2 entries)
| DescDesc | AmtAmt |
|---|---|
| EMPLOYEE BENEFITS PAYABLE | $6,802,555 |
| DEFERRED RENT & CONSTRUCTION ALLOWANCES | $4,549,818 |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total Liability | $11,352,373 | TotalLiabilityAmt |
| Footnote Text | Yes (X) | FootnoteTextInd |
| Total Rev Etc Audited Fincl Stmt | $48,917,391 | TotalRevEtcAuditedFinclStmtAmt |
| Net Unrealized Gains Invst | $1,260,210 | NetUnrealizedGainsInvstAmt |
| Revenue Not Reported | $1,260,210 | RevenueNotReportedAmt |
| Revenue Subtotal | $47,657,181 | RevenueSubtotalAmt |
| Revenue Not Reported Fincl Stmt | $0 | RevenueNotReportedFinclStmtAmt |
| Total Revenue Per Form990 | $47,657,181 | TotalRevenuePerForm990Amt |
| Tot Expns Etc Audited Fincl Stmt | $49,586,818 | TotExpnsEtcAuditedFinclStmtAmt |
| Other Expenses Included | $296,345 | OtherExpensesIncludedAmt |
| Expenses Not Reported | $296,345 | ExpensesNotReportedAmt |
| Expenses Subtotal | $49,290,473 | ExpensesSubtotalAmt |
| Expenses Not Rpt Fincl Stmt | $0 | ExpensesNotRptFinclStmtAmt |
| Total Expenses Per Form990 | $49,290,473 | TotalExpensesPerForm990Amt |
Supplemental Information Detail SupplementalInformationDetail (3 entries)
| Form And Line ReferenceFormAndLineReferenceDesc | ExplanationExplanationTxt |
|---|---|
| PART IV, LINE 2B: | CUSTODIAL ARRANGEMENTS IN ORDER TO FINANCE CERTAIN MEMBER DRIVEN PROJECTS THAT ARE BEYOND SIFMA'S OPERATING BUDGET RESOURCES AND WHICH IMPACT ONLY A SUBSET OF MEMBERS, SIFMA SYNDICATES OUT SUCH PROJECT COSTS TO PARTICIPATING MEMBER FIRMS. THIRD-PARTY PROJECT COSTS (AND ASSOCIATED MEMBER REIMBURSEMENTS) ARE INCLUDED IN SIFMA'S BALANCE SHEET. IN 2021, THE SYNDICATED FUNDS COLLECTED FROM MEMBERS AND DISBURSED FOR SUCH SPECIAL PROJECTS TOTALED $1,979,505 AND $2,136,509, RESPECTIVELY. |
| PART X, LINE 2: | FIN 48 THE ASSOCIATION FOLLOWS GUIDANCE THAT CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS GUIDANCE PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN ONLY BE RECOGNIZED IN THE FINANCIAL STATEMENTS IF THE POSITION IS "MORE-LIKELY-THAN-NOT" TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE ASSOCIATION IS EXEMPT FROM FEDERAL INCOME TAX UNDER SECTION 501(C)(6) OF THE INTERNAL REVENUE CODE, THOUGH IT IS SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. THE ASSOCIATION HAS PROCESSES PRESENTLY IN PLACE TO ENSURE THE MAINTENANCE OF ITS TAX-EXEMPT STATUS; TO IDENTIFY AND REPORT UNRELATED INCOME; TO DETERMINE ITS FILING AND TAX OBLIGATIONS IN JURISDICTIONS FOR WHICH IT HAS NEXUS; AND TO IDENTIFY AND EVALUATE OTHER MATTERS THAT MAY BE CONSIDERED TAX POSITIONS. THE ASSOCIATION HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS. |
| PART XII, LINE 2D - OTHER ADJUSTMENTS: | NET PERIODIC POST RETIREMENT BENEFIT COST 296,345. |
Schedule I IRS990ScheduleI
| Field | Value | IRS element (for citing) |
|---|---|---|
| Grant Records Maintained | Yes (1) | GrantRecordsMaintainedInd |
Recipient Table RecipientTable (11 entries)
| Address Line1USAddress/AddressLine1Txt | CityUSAddress/CityNm | State AbbreviationUSAddress/StateAbbreviationCd | ZIPUSAddress/ZIPCd | Recipient EINRecipientEIN | IRC SectionIRCSectionDesc | Cash GrantCashGrantAmt | Purpose Of GrantPurposeOfGrantTxt |
|---|---|---|---|---|---|---|---|
| COMMITTEE ON CAPITAL MARKETS REGULATION INC | |||||||
| 134 MOUNT AUBURN STREET | CAMBRIDGE | MA | 02138 | 300406260 | 501(C)(3) | $50,000 | PROGRAM SUPPORT |
| FORMER MEMBERS OF CONGRESS INC | |||||||
| 1401 K STREET NW SUITE 503 | WASHINGTON | DC | 20005 | 540883744 | 501(C)(3) | $8,000 | PROGRAM SUPPORT |
| NATIONAL ADULT PROTECTION SERVICES ASSOCIATION | |||||||
| 1612 K STREET NW 200 | WASHINGTON | DC | 20006 | 300044497 | 501(C)(3) | $18,000 | PROGRAM SUPPORT |
| NCSL FOUNDATION FOR STATE LEGISLATURES | |||||||
| 7700 EAST FIRST PLACE | DENVER | CO | 80230 | 742232576 | 501(C)(3) | $7,500 | PROGRAM SUPPORT |
| PREVENT CANCER FOUNDATION | |||||||
| 1600 DUKE STREET SUITE 500 | ALEXANDRIA | VA | 22314 | 521429544 | 501(C)(3) | $10,000 | PROGRAM SUPPORT |
| PROGRAM ON INTERNATIONAL FINANCIAL SYSTEM INC | |||||||
| 134 MT AUBURN STREET | CAMBRIDGE | MA | 02138 | 822586755 | 501(C)(3) | $10,000 | PROGRAM SUPPORT |
| SEC HISTORICAL SOCIETY | |||||||
| 1101 PENNSYLVANIA AVE NW STE 600 | WASHINGTON | DC | 20004 | 522213646 | 501(C)(3) | $10,000 | PROGRAM SUPPORT |
| SIFMA FOUNDATION FOR INVESTOR EDUCATION (FIE) INC | |||||||
| 140 BROADWAY | NEW YORK | NY | 10005 | 521087193 | 501(C)(3) | $15,000 | PROGRAM SUPPORT |
| THE MEMORIAL FOUNDATION INC | |||||||
| 633 PENNSYLVANIA AVE NW FL 3 | WASHINGTON | DC | 20004 | 460758941 | 501(C)(3) | $15,000 | PROGRAM SUPPORT |
| UNITED STATES CAPITOL HISTORICAL SOCIETY | |||||||
| 200 MARYLAND AVE NE | WASHINGTON | DC | 20002 | 520796820 | 501(C)(3) | $10,000 | PROGRAM SUPPORT |
| WOMENS INSTITUTE FOR A SECURE RETIREMENT | |||||||
| 1140 19TH STREET NW SUITE 550 | WASHINGTON | DC | 20036 | 521997317 | 501(C)(3) | $20,000 | PROGRAM SUPPORT |
| Field | Value | IRS element (for citing) |
|---|---|---|
| Total501c3 Org | 11 | Total501c3OrgCnt |
| Total Other Org | 0 | TotalOtherOrgCnt |
Supplemental Information Detail SupplementalInformationDetail
| Field | Value | IRS element (for citing) |
|---|---|---|
| Form And Line Reference | PART I, LINE 2: | FormAndLineReferenceDesc |
| Explanation | GRANT MONITORING SIFMA PROVIDES SUPPORT TO CHARITABLE ORGANIZATIONS TO HELP THOSE ORGANIZATIONS FURTHER THEIR EXEMPT PROGRAMS. SIFMA IS NOT A GRANT MAKING ORGANIZATION BUT WILL OCCASIONALLY AWARD A GRANT TO ORGANIZATIONS IN SUPPORT OF A PROJECT THAT ALIGNS ITSELF WITH SIFMA'S MISSION OF PROMOTING AND SUPPORTING A STRONG FINANCIAL INDUSTRY. SIFMA MAINTAINS IN ITS RECORDS THE ACKNOWLEDGMENT LETTER FROM THE RECIPIENT ORGANIZATION AND ANY FOLLOW UP REPORTS ON THE USE OF GRANT FUNDS. | ExplanationTxt |
Schedule J IRS990ScheduleJ
| Field | Value | IRS element (for citing) |
|---|---|---|
| First Class Or Charter Travel | Yes (X) | FirstClassOrCharterTravelInd |
| Written Policy Ref T And E Expnss | Yes (1) | WrittenPolicyRefTAndEExpnssInd |
| Substantiation Required | Yes (1) | SubstantiationRequiredInd |
| Compensation Committee | Yes (X) | CompensationCommitteeInd |
| Independent Consultant | Yes (X) | IndependentConsultantInd |
| Compensation Survey | Yes (X) | CompensationSurveyInd |
| Board Or Committee Approval | Yes (X) | BoardOrCommitteeApprovalInd |
| Severance Payment | 0 | SeverancePaymentInd |
| Supplemental Nonqual Rtr Plan | Yes (1) | SupplementalNonqualRtrPlanInd |
| Equity Based Comp Arrngm | 0 | EquityBasedCompArrngmInd |
Rltd Org Officer Trst Key Empl RltdOrgOfficerTrstKeyEmplGrp (12 entries)
| TitleTitleTxt | Base Compensation Filing OrgBaseCompensationFilingOrgAmt | Compensation Based On Rltd OrgsCompensationBasedOnRltdOrgsAmt | Bonus Filing OrganizationBonusFilingOrganizationAmount | Bonus Related OrganizationsBonusRelatedOrganizationsAmt | Other Compensation Filing OrgOtherCompensationFilingOrgAmt | Other Compensation Rltd OrgsOtherCompensationRltdOrgsAmt | Deferred Compensation Flng OrgDeferredCompensationFlngOrgAmt | Deferred Comp Rltd OrgsDeferredCompRltdOrgsAmt | Nontaxable Benefits Filing OrgNontaxableBenefitsFilingOrgAmt | Nontaxable Benefits Rltd OrgsNontaxableBenefitsRltdOrgsAmt | Total Compensation Filing OrgTotalCompensationFilingOrgAmt | Total Compensation Rltd OrgsTotalCompensationRltdOrgsAmt | Comp Report Prior990 Filing OrgCompReportPrior990FilingOrgAmt | Comp Report Prior990 Rltd OrgsCompReportPrior990RltdOrgsAmt |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| KENNETH E BENTSEN JR | ||||||||||||||
| PRESIDENT & CEO | $1,488,142 | $0 | $925,000 | $0 | $5,544 | $0 | $34,200 | $0 | $37,215 | $0 | $2,490,101 | $0 | $0 | $0 |
| JOSEPH SEIDEL | ||||||||||||||
| COO | $688,978 | $0 | $400,000 | $0 | $4,356 | $0 | $34,200 | $0 | $43,278 | $0 | $1,170,812 | $0 | $0 | $0 |
| IRA D HAMMERMAN | ||||||||||||||
| EVP/GC (SEE SCH. J 457 FN) | $482,162 | $0 | $400,000 | $0 | $100,140 | $0 | $34,200 | $0 | $45,492 | $0 | $1,061,994 | $0 | $0 | $0 |
| DAVID B KRASNER | ||||||||||||||
| CFO & CAO | $393,978 | $0 | $295,000 | $0 | $3,612 | $0 | $34,200 | $0 | $46,849 | $0 | $773,639 | $0 | $0 | $0 |
| TIMOTHY W CAMERON | ||||||||||||||
| MANAGING DIRECTOR | $432,222 | $0 | $190,000 | $0 | $5,544 | $0 | $34,200 | $0 | $36,329 | $0 | $698,295 | $0 | $0 | $0 |
| JAMIE WALL | ||||||||||||||
| EXECUTIVE VICE PRESIDENT | $463,950 | $0 | $135,000 | $0 | $594 | $0 | $34,200 | $0 | $2,778 | $0 | $636,522 | $0 | $0 | $0 |
| CHERYL L CRISPEN | ||||||||||||||
| EXECUTIVE VICE PRESIDENT | $363,554 | $0 | $227,500 | $0 | $3,612 | $0 | $34,200 | $0 | $4,750 | $0 | $633,616 | $0 | $0 | $0 |
| MARK SCHUERMANN | ||||||||||||||
| MANAGING DIRECTOR | $457,666 | $0 | $100,000 | $0 | $2,838 | $0 | $34,200 | $0 | $18,405 | $0 | $613,109 | $0 | $0 | $0 |
| ROBERT TOOMEY | ||||||||||||||
| MANAGING DIRECTOR | $376,758 | $0 | $145,000 | $0 | $5,544 | $0 | $36,669 | $0 | $45,499 | $0 | $609,470 | $0 | $0 | $0 |
| VICTORIA CUMINGS | ||||||||||||||
| MANAGING DIRECTOR | $344,708 | $0 | $173,000 | $0 | $990 | $0 | $34,200 | $0 | $17,104 | $0 | $570,002 | $0 | $0 | $0 |
| CARTER K MCDOWELL | ||||||||||||||
| MANAGING DIRECTOR | $414,030 | $0 | $80,000 | $0 | $5,544 | $0 | $34,200 | $0 | $34,025 | $0 | $567,799 | $0 | $0 | $0 |
| SALVATORE CHIARELLI | ||||||||||||||
| EXECUTIVE VICE PRESIDENT | $226,055 | $0 | $145,000 | $0 | $1,932 | $0 | $34,200 | $0 | $33,709 | $0 | $440,896 | $0 | $0 | $0 |
Supplemental Information Detail SupplementalInformationDetail (2 entries)
| Form And Line ReferenceFormAndLineReferenceDesc | ExplanationExplanationTxt |
|---|---|
| PART I, LINE 1A | FIRST-CLASS TRAVEL PER THE EMPLOYMENT CONTRACT, SIFMA PROVIDED FIRST CLASS AIR TRAVEL WHEN TRAVELING FOR SIFMA BUSINESS FOR KENNETH E. BENTSEN, JR., PRESIDENT AND CEO. THE FIRST-CLASS AIR TRAVEL WAS EXCLUDED FROM TAXABLE COMPENSATION ON THE INDIVIDUAL'S FORM W-2 BECAUSE IT WAS INCURRED FOR BUSINESS REASONS. |
| PART I, LINE 4B | SUPPLEMENTAL NONQUALIFIED RETIREMENT PLAN EVP AND GENERAL COUNSEL PARTICIPATES IN A 457(F) PLAN. HE RECEIVED A TAXABLE PAYMENT OF $94,596 IN HIS 2020 W-2. |
Schedule O IRS990ScheduleO
Supplemental Information Detail SupplementalInformationDetail (15 entries)
| Form And Line ReferenceFormAndLineReferenceDesc | ExplanationExplanationTxt |
|---|---|
| FORM 990, PART I, LINE 1, DESCRIPTION OF ORGANIZATION MISSION: | AND ASSET MANAGERS OPERATING IN THE U.S. AND GLOBAL CAPITAL MARKETS. |
| FORM 990, PART I, LINE 6: | VOLUNTEERS THE NUMBER OF VOLUNTEERS WAS DERIVED FROM SIFMA COMMITTEE PARTICIPANTS PER THE MEMBERSHIP DATABASE. |
| FORM 990, PART III, LINE 4A | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS CONTINUED DEVELOPMENT AND MAINTENANCE OF BEST PRACTICES THAT ARE CONDUCIVE TO EFFICIENT CONDUCT OF THE BUSINESS AND MEMBERS OF THE ORGANIZATION: BUSINESS CONTINUITY PLANNING: SIFMA AND ITS MEMBER FIRMS ARE DEDICATED TO PREPARING FOR THE RISK OF POTENTIAL DISRUPTIONS TO AT BOTH THE FIRM AND BROADER MARKET LEVELS. SIFMA PLAYS A KEY ROLE IN COORDINATING THE INDUSTRY'S RESPONSE TO INCIDENTS THAT CAN INTERRUPT BUSINESS AND MARKET FUNCTIONS AND WORKS TO SUPPORT FIRM-LEVEL BCP PLANNING AS WELL. FINANCIAL SERVICES IS A CRITICAL INFRASTRUCTURE SECTOR AS IDENTIFIED BY THE U.S. DEPARTMENT OF HOMELAND SECURITY. INDUSTRY-WIDE BUSINESS CONTINUITY TEST: THE INDUSTRY-WIDE BUSINESS CONTINUITY TEST IS A CRITICAL EXERCISE THAT HIGHLIGHTS OUR INDUSTRY'S ABILITY TO OPERATE THROUGH A SIGNIFICANT EMERGENCY USING BACKUP SITES, RECOVERY FACILITIES AND BACKUP COMMUNICATIONS CAPABILITIES ACROSS THE INDUSTRY. THE TEST IS SUPPORTED BY ALL MAJOR EXCHANGES, MARKET, AND INDUSTRY UTILITIES. IT INVOLVES TEST TRANSACTIONS FOR COMMERCIAL PAPER, EQUITIES, OPTIONS, FUTURES, FIXED INCOME, SETTLEMENT, PAYMENTS, TREASURY AUCTIONS AND MARKET DATA. SIFMA ALSO FACILITATES A COORDINATED REG SCI TESTING PROGRAM WHICH IS COMPLETED IN PARALLEL WITH THE SIFMA INDUSTRY TEST. THE TEST OCCURS ON THE SAME DAY AS FUTURES MARKET TESTING COORDINATED BY THE FUTURES INDUSTRY ASSOCIATION (FIA), AND ON ALTERNATE YEARS WITH CANADIAN MARKET PARTICIPANT TEST THROUGH THE INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA (IIROC). THE INDUSTRY SUCCESSFULLY COMPLETED THE 2021 TEST ON OCTOBER 23; THE 2022 TEST WILL BE HELD ON OCTOBER 15, 2022. EMERGENCY CRISIS MANAGEMENT COMMAND CENTER: IN THE EVENT OF AN INDUSTRY-WIDE INCIDENT, SIFMA CONVENES MARKET PARTICIPANTS; ISSUES MARKET CLOSE RECOMMENDATIONS; AND COORDINATES WITH MARKET INFRASTRUCTURE PROVIDERS, REGULATORS AND EMERGENCY PERSONNEL INCLUDING THE U.S. TREASURY, NEW YORK CITY OFFICE OF EMERGENCY MANAGEMENT, LAW ENFORCEMENT AND MORE. SIFMA ORGANIZES MARKET RESPONSE COMMITTEES FOR THE FIXED INCOME AND EQUITY MARKETS TO DELIVER AN INDUSTRY PERSPECTIVE IN THE EVENT OF DISRUPTIONS TO MARKET INFRASTRUCTURE WHICH MAY MAKE UNSCHEDULED MARKET CLOSES OR CHANGES TO SETTLEMENT CONVENTION NECESSARY. THE COMMITTEES HAVE DEVELOPED PRINCIPLES AND OBJECTIVE DECISION MAKING PROCESSES THAT RECOGNIZE THE SIGNIFICANT IMPROVEMENTS THE INDUSTRY HAS MADE WITH RESPECT TO BUSINESS CONTINUITY AND THE EXPECTATIONS OF REGULATORS. THESE PRINCIPLES ALSO REFLECT EXPECTATIONS FOR STRONG RESILIENCY PLANS OF CRITICAL FINANCIAL MARKET INFRASTRUCTURE AND FINANCIAL INSTITUTIONS. FOR FIXED INCOME, THE COMMITTEE HAS DEVELOPED PROCEDURES TO DETERMINE IF IT NECESSARY FOR SIFMA RECOMMEND AN UNSCHEDULED CLOSE IN U.S. FIXED INCOME MARKETS. CYBERSECURITY: CYBERATTACKS DID NOT STOP DURING THE PANDEMIC. RATHER, THEY INCREASED. FROM WANNACRY TO SOLARWINDS, ATTACKS HAVE GOTTEN BOLDER AND THEIR THREAT HAS GROWN HIGHER. HOWEVER, INDUSTRY-WIDE EFFORTS OVER THE LAST DECADE HAVE ALSO EVOLVED AND GROWN TO BUILD EFFECTIVE CYBER DEFENSES. CYBERSECURITY IS A TOP PRIORITY. THE FINANCIAL INDUSTRY WORKS TIRELESSLY TO SECURE CUSTOMER ASSETS AND INFORMATION, AND THE EFFICIENT, RELIABLE EXECUTION OF TRANSACTIONS WITHIN MARKETS. ON BEHALF OF THE FINANCIAL INDUSTRY, SIFMA'S SEEKS TO: (1) PROMOTE ENHANCED REGULATORY HARMONIZATION TO ENCOURAGE A MORE EFFECTIVE ALLOCATION OF CYBER RESOURCES; (2) PROMOTE A ROBUST INDUSTRY-GOVERNMENT PARTNERSHIP GROUNDED IN INFORMATION SHARING; (3) DESIGN EXERCISES AND INDUSTRY TESTS TO IMPROVE PROTOCOLS FOR INCIDENT PREPAREDNESS, RESPONSE AND RECOVERY; AND (4) USE THE LESSONS LEARNED TO REFINE INDUSTRY BEST PRACTICES, INCLUDING FOR MANAGING INSIDER THREATS, THIRD PARTY RISK; PENETRATION TESTING AND DATA SECURITY, INCLUDING SECURE DATA STORAGE AND RECOVERY. SHORTENED SETTLEMENT CYCLES: ENHANCING OUR SECURITIES SETTLEMENT PROCESS IS CRITICAL TO THE CONTINUED RESILIENCY OF OUR MARKETS AND MARKET OPERATIONS. U.S. EQUITY MARKET TRADES CURRENTLY SETTLE TWO BUSINESS DAYS AFTER THE TRADE IS EXECUTED (T+2). FOLLOWING ON OUR SUCCESSFUL WORK TO MOVE THE INDUSTRY FROM T+3 TO T+2, SIFMA, THE INVESTMENT COMPANY INSTITUTE (ICI), AND THE DEPOSITORY TRUST & CLEARING CORPORATION (DTCC) ARE COLLABORATING ON EFFORTS TO ACCELERATE THE U.S. SECURITIES SETTLEMENT CYCLE FROM T+2 TO T+1, A PROCESS WHICH SHOULD BE COMPLETED IN THE FIRST HALF OF 2024. WHY THIS MASSIVE UNDERTAKING? T+1 SETTLEMENT CYCLE WILL MITIGATE SETTLEMENT RISK WELL BEYOND WHAT WAS ACHIEVED UNDER T+2. IN ADDITION, A MOVE TO T+1 WILL INCREASE SETTLEMENT EFFICIENCIES AND IMPROVE THE USE OF CAPITAL, ESPECIALLY IN PERIODS OF HIGH VOLATILITY, FOR INSTANCE AS SEEN DURING THE PARTICULARLY VOLATILE PERIODS IN MARCH 2021. MOVING FORWARD ON BOTH THE INTEGRATED SETTLEMENT MODEL AND MOVING TO A T+1 SETTLEMENT CYCLE WILL BE A SUBSTANTIAL UNDERTAKING REQUIRING BROAD INDUSTRY ACTIONS. IN 2021, THE ORGANIZATIONS CONDUCTED AN ANALYSIS AND OUTLINED KEY STEPS TO SHORTEN THE CYCLE TO T+1, IDENTIFYING PRIORITY ISSUES THAT MUST BE ADDRESSED AND CONDUCTING THE NECESSARY DUE DILIGENCE AND RESOLUTION OF THESE CRITICAL ISSUES. NOW, WE ARE EXECUTING ON A PLAN TO UNDERTAKE DEVELOPING THE PLAN OUTLINING THE NECESSARY STEPS AND TIMEFRAMES TO MOVE THE INDUSTRY TO T+1. WE WILL WORK CLOSELY WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION TO ADOPT NECESSARY CHANGES INCLUDING AN AMENDMENT TO THE SETTLEMENT CYCLE RULE (RULE 15C6-1(A)) UNDER THE SECURITIES EXCHANGE ACT OF 1934. |
| FORM 990, PART III, LINE 4B | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS ADVOCACY: ADVOCACY FOR ISSUES OF IMPORTANCE TO ITS MEMBERS: SIFMA BRINGS TOGETHER THE SHARED INTERESTS OF HUNDREDS OF BROKER-DEALERS, BANKS AND ASSET MANAGERS. WE ADVOCATE IN SUPPORT OF EFFECTIVE AND RESILIENT CAPITAL MARKETS. SIFMA, ON BEHALF OF THE FINANCIAL SERVICES INDUSTRY, ENGAGES WITH POLICYMAKERS AND REGULATORS ON A STATE, FEDERAL AND GLOBAL LEVEL THROUGH COMMENT LETTERS, TESTIMONY, STUDIES AND MORE. SIFMA'S GOAL IS TO ENSURE REGULATION IS EFFECTIVE, BALANCED AND CONSISTENT WITH ITS INTENDED PURPOSE, APPROPRIATELY COORDINATED WITH OTHER REGULATORS AND REGULATORY REGIMES, AND AVOIDS CONSTRAINING CAPITAL FORMATION AND CREDIT AVAILABILITY, OR OTHERWISE IMPEDING THE FUNCTIONING OF THE MARKETS AND THE INDIVIDUALS THEY SERVE. FINANCING SUSTAINABILITY: THE NEED TO FINANCE A PATH TO A SUSTAINABLE FUTURE HAS NEVER FELT MORE URGENT. IT IS ESTIMATED THAT $60 TRILLION IS NEEDED TO MEET THE SEVENTEEN SUSTAINABLE DEVELOPMENT GOALS OUTLINED BY THE UNITED NATIONS. NO SINGLE ENTITY CAN ACHIEVE THESE GOALS ALONE. RESPONSIBLE INVESTMENT IS AN APPROACH TO INVESTMENT THAT EXPLICITLY ACKNOWLEDGES THE RELEVANCE OF ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) FACTORS TO THE PERFORMANCE AND PROFITABILITY OF INVESTMENT AND TO THE LONG-TERM HEALTH AND STABILITY OF THE MARKET AS A WHOLE. IT RECOGNIZES THAT THE GENERATION OF LONG-TERM SUSTAINABLE RETURNS IS DEPENDENT ON STABLE, WELL-FUNCTIONING AND WELL GOVERNED SOCIAL, ENVIRONMENTAL AND ECONOMIC SYSTEMS. ESG IS INCREASINGLY SHAPING THE WAY BOTH INDIVIDUAL AND INSTITUTIONAL INVESTORS CHOOSE TO ENGAGE WITH COMPANIES AND THUS IMPACTING HOW COMPANIES DO BUSINESS AROUND THE WORLD. AS INVESTORS HAVE ALIGNED THEIR INVESTMENTS WITH THEIR VALUES, BROKERAGE FIRMS AND MUTUAL FUND COMPANIES HAVE SIGNIFICANTLY INCREASED THEIR OFFERINGS OF EXCHANGE-TRADED FUNDS (ETFS) AND OTHER FINANCIAL PRODUCTS TO SUPPORT INVESTOR AND CLIENT NEEDS. INFLOWS INTO SUSTAINABLE INVESTMENT FUNDS HAVE OUTPACED ALL FLOWS AND, IMPORTANTLY, INVESTORS INCREASINGLY BELIEVE THAT SUSTAINABLE INVESTMENTS OFFER GREATER RETURNS THAN CONVENTIONAL INVESTING. TRANSITIONING FROM LIBOR: THE FINANCIAL INDUSTRY AND GLOBAL REGULATORS ARE TRANSITIONING FROM THE LONDON INTERBANK OFFERED RATE (LIBOR) TO MORE ROBUST ALTERNATIVE REFERENCE RATES. LIBOR IS THE MOST COMMONLY USED BENCHMARK FOR SHORT-TERM INTEREST RATES, OFTEN REFERENCED GLOBALLY IN DERIVATIVE, BOND AND LOAN DOCUMENTATION. IT IS ESTIMATED THAT $223 TRILLION OF FINANCIAL CONTRACTS AND SECURITIES ARE TIED TO USD LIBOR AND THAT MATTERS TO EVERYONE SMALL BUSINESSES, CORPORATIONS, BANKS, BROKER DEALERS, CONSUMERS, AND INVESTORS. THE TRANSITION FROM LIBOR TO ALTERNATIVE INTEREST RATE BENCHMARKS IS WELL UNDERWAY, BUT MUCH WORK LIES AHEAD. LIBOR IS REFERENCED BY APPROXIMATELY $223 TRILLION OF FINANCIAL PRODUCTS. TODAY'S LIBOR IS INFORMED PRIMARILY (AND SOMETIMES ENTIRELY) BY "EXPERT JUDGEMENT" FROM ESTIMATES OF TRANSACTIONS, NOT ACTUAL TRANSACTIONS. AS A RESULT, LIBOR DOESN'T NECESSARILY REFLECT THE TRUE COST OF BANK FUNDING AND IS VULNERABLE TO VOLATILITY AND MANIPULATION. GLOBAL REGULATORS SAW THE PROBLEM WITH PLACING THE FOUNDATION FOR GLOBAL FINANCIAL MARKETS ON SUCH A CONSTRUCT NEARLY A DECADE AGO, AND THEY BEGAN TO EXAMINE HOW MORE ROBUST ALTERNATIVE REFERENCE RATES COULD BE IDENTIFIED OR DEVELOPED TO REPLACE LIBOR. AS SUCH, THE REGULATORY COMMUNITY CONTINUES TO BELIEVE THAT LIBOR IS NOT A SUITABLE RATE AND MARKET PARTICIPANTS MUST TRANSITION TO ALTERNATIVE REFERENCE RATES. IMPROVING CAPACITY AND RESILIENCY IN US TREASURY MARKETS: RECENT EVENTS HIGHLIGHTED LONGER-TERM STRUCTURAL QUESTIONS IN THE TREASURY MARKETS, PARTICULARLY THE GROWING MISMATCH BETWEEN THE VOLUME OF TREASURY ISSUANCE AND THE CAPACITY OF THE SYSTEM TO INTERMEDIATE THE TRADING OF THOSE INSTRUMENTS. HOW TREASURY MARKET LIQUIDITY CAN BE MAINTAINED, EVEN DURING PERIODS OF STRESS, IS THE SUBJECT OF SIGNIFICANT STUDY AND DEBATE. U.S. TREASURIES ARE DEBT INSTRUMENTS ISSUED BY THE U.S. GOVERNMENT TO FINANCE ITS ACTIVITIES. OWING TO THE UNITED STATES' CREDITWORTHINESS AND STATUS AS THE WORLD'S LEADING ECONOMY, THE U.S. TREASURY MARKET (COMPRISED OF THE CASH MARKET AS WELL AS THE REPURCHASE AGREEMENT ("REPO") AND FUTURES MARKETS) HAS BEEN DESCRIBED AS THE "BIGGEST, DEEPEST AND MOST ESSENTIAL BOND MARKET ON THE PLANET." INVESTORS VIEW TREASURIES HISTORICALLY AS RISK-FREE OR NEAR-CASH ASSETS I.E., ASSETS THAT RETAIN THEIR VALUE AND CAN BE EASILY SOLD DURING BOTH NORMAL AND STRESSED MARKET PERIODS. UNSURPRISINGLY THEN, TREASURIES HAVE TENDED TO BE VIEWED AS SAFE HAVENS FOR INVESTORS DURING MARKET CRISES. OWING TO THEIR STABILITY, U.S. TREASURIES ALSO OFTEN SERVE AS BENCHMARKS FOR OTHER FIXED-INCOME SECURITIES AND HEDGING POSITIONS; AS A RESULT, U.S. TREASURY YIELDS HAVE AN IMPACT ON THE RATES THAT CONSUMERS, BUSINESSES, AND GOVERNMENTS ACROSS THE GLOBE PAY TO BORROW MONEY. IN ADDITION, THE U.S. TREASURY REPO MARKET IS A KEY TRANSMISSION MECHANISM FOR U.S. MONETARY POLICY, AND VITAL TO THE LIQUIDITY OF THE CASH TREASURY MARKET. PUT SIMPLY, THE U.S. TREASURY MARKET IS A BEDROCK OF THE GLOBAL FINANCIAL SYSTEM. THE RESILIENCY OF THE TREASURY MARKETS HAS BEEN CALLED INTO QUESTION BY A SERIES OF MARKET DISRUPTION EVENTS IN WHICH MARKET PRICE VOLATILITY INCREASED DRAMATICALLY AND/OR WHERE THE DEPTH OF THE MARKET (I.E., THE AMOUNT OF LIQUIDITY AVAILABLE) DECREASED PRECIPITOUSLY. THESE INCLUDE THE "FLASH RALLY" IN OCTOBER 2014, STRESSES IN THE TREASURY-BACKED REPO MARKETS IN SEPTEMBER 2019, AND THE "DASH-FOR-CASH" IN MARCH 2020. WHILE THESE EVENTS HAVE DIFFERED IN THEIR SCOPE AND MAGNITUDE, COLLECTIVELY THEY HAVE HIGHLIGHTED A VARIETY OF UNDERLYING STRUCTURAL PROBLEMS IN THE TREASURY MARKETS. THIS HAS LED TO CALLS FOR REFORMS. ENSURING DEEP AND LIQUID EQUITY MARKETS: THERE HAS NEVER BEEN A BETTER TIME TO BE AN INVESTOR. THE U.S. EQUITY MARKETS CONTINUE TO BE AMONG THE DEEPEST, MOST LIQUID AND MOST EFFICIENT IN THE WORLD, WITH INVESTORS ENJOYING NARROW SPREADS, LOW TRANSACTION COSTS AND FAST EXECUTION SPEEDS. INVESTORS ALSO BENEFIT FROM ZERO COMMISSIONS WHICH HAS HELPED TO DEMOCRATIZE THE EQUITY MARKETS BY PROVIDING ACCESS TO NEW INVESTORS AS EVIDENCED BY THE GROWTH IN RETAIL TRADING. NOT ONLY DO RETAIL INVESTORS BENEFIT FROM INEXPENSIVE ACCESS TO THE MARKETS, BUT THEY ALSO ENJOY PRICE AND SIZE IMPROVEMENT WHEN COMPARED WITH THE NATIONAL BEST BID OR OFFER (NBBO). EFFICIENT AND RESILIENT MARKET STRUCTURE IS KEY TO SUSTAINING INVESTOR CONFIDENCE AND PARTICIPATION IN THE EQUITY MARKETS. EQUITY MARKETS ARE THE PUBLIC FACE OF FINANCE AND ARE OFTEN SEEN AS A BAROMETER OF THE OVERALL HEALTH OF THE ECONOMY. IN THAT SENSE, A THRIVING MARKET FOR NEW ISSUES OF PUBLICLY OFFERED EQUITY SECURITIES, INCLUDING THE INITIAL PUBLIC OFFERING (IPO) MARKET AND DIRECT LISTINGS, IS PERHAPS THE MOST DIRECT AND TANGIBLE EVIDENCE OF AN ECONOMY WHERE NEW BUSINESSES HAVE CONFIDENCE IN THEIR FUTURE PROSPECTS. BUSINESSES MOST OFTEN SEEK TO ACCESS A LARGER POOL OF PUBLIC CAPITAL TO ALLOW FOR THE NEXT STAGE OF THEIR GROWTH AND, IDEALLY, JOB CREATION FOLLOWS. HELPING MORE AMERICANS REACH THEIR FINANCIAL GOALS: THE U.S. CAPITAL MARKETS ARE WHERE PEOPLE INDIVIDUALLY AND COLLECTIVELY THROUGH PENSION FUNDS AND MUTUAL FUNDS INVEST THEIR SAVINGS TO SEEK A RETURN. WORKING WITH OUR MEMBERS IN THE WEALTH MANAGEMENT SPACE, SIFMA SEEKS TO RAISE AWARENESS OF HOW FINANCIAL ADVICE AND FINANCIAL LITERACY PROGRAMS CAN POSITIVELY IMPACT THE FINANCIAL HEALTH OF AMERICANS WORKING TO REACH THEIR FINANCIAL GOALS, INCLUDING PURCHASING A HOME, SENDING CHILDREN TO COLLEGE AND SAVING FOR RETIREMENT. RESEARCH SHOWS THAT A WIDE UNIVERSE OF AMERICANS TODAY OWN STOCKS. FEDERAL RESERVE DATA FROM 2019 SHOWS 52.6% OF AMERICANS OWN STOCKS, OR 65 MILLION HOUSEHOLDS AND A GALLUP POLL CONDUCTED IN MARCH/APRIL 2020 INDICATES THIS NUMBER MAY NOW BE EVEN HIGHER AT 55%. ON THE FLIP SIDE, 2019 FEDERAL RESERVE DATA SHOWS A MEDIAN VALUE OF $40K FOR A HOUSEHOLD'S STOCK HOLDINGS. THIS CLEARLY TELLS US THAT MANY AMERICAN FAMILIES ARE INVESTED IN THE MARKET BUT TO ADDRESS RETIREMENT NEEDS THESE NUMBERS SHOULD BE HIGHER, BOTH IN TERMS OF ACCOUNT HOLDINGS AND NUMBER OF HOUSEHOLDS. THE MOVE TO DIGITIZATION: U.S. CAPITAL MARKETS HAVE CONTINUED TO INNOVATE AS TECHNOLOGY HAS ALLOWED FOR PROFOUND EVOLUTIONS IN MARKET INFRASTRUCTURE, CHANGING AT TIMES THE VERY NATURE OF AMERICAN FINANCIAL MARKETS. AT THE PEAK OF THE PANDEMIC, MORE THAN 90% OF THE FINANCIAL SERVICES INDUSTRY WORKED REMOTELY, ACCELERATING DIGITAL ADOPTION THROUGH INTENSIFIED FOCUS AND TRANSITION ON PRIORITIES EVIDENT BEFORE THE PANDEMIC. AS MOVE THROUGH, AND HOPEFULLY BEYOND COVID-19, INDUSTRY EFFORTS HAVE SHIFTED TO RETURNING TO THE OFFICE AND WE EXPECT THE PACE OF CHANGE TO ONLY INCREASE. JUST SOME OF THE DEVELOPMENTS AHEAD INCLUDE: |
| FORM 990, PART III, LINE 4B | (1) E-DELIVERY: AS THE INDUSTRY MOVES TOWARD FURTHER SHORTENING THE SETTLEMENT CYCLE, E-DELIVERY WILL ONLY BECOME MORE NECESSARY, AND WE ARE ENGAGING WITH THE SEC TO MAKE IT EASIER FOR MARKET PARTICIPANTS TO MAKE THIS TRANSITION. (2) DIGITAL ASSETS: DIGITAL ASSETS ARE AT A PIVOTAL POINT IN OUR INDUSTRY. WE EXPECT THE INCREASING CONSUMER AND REGULATORY INTEREST IN CRYPTO AND DIGITAL ASSETS TO LEAD TO NEW PRODUCTS, RULES AND REQUIREMENTS FOR BROKER DEALERS, BANKS, AND ASSET MANAGERS. (3) DISTRIBUTED LEDGER TECHNOLOGY (DLT): THE POTENTIAL BENEFIT DLT COULD BRING TO THE CAPITAL MARKET ECOSYSTEM AND INFRASTRUCTURE ARE A KEY TOPIC OF INTEREST AMONGST MARKET PARTICIPANTS. (4) SHEDDING LEGACY SYSTEMS AND MANUAL PROCESSES: FINANCIAL SERVICES FIRMS ARE EMBRACING THE CLOUD AND OTHER DIGITAL PLATFORMS TO GO PAPERLESS, INCREASE OPERATIONAL EFFICIENCIES AND SPEED TO DELIVERY. (5) TRANSFORMING THE CUSTOMER EXPERIENCE: NEW CAPABILITIES ARE NEEDED TO ANTICIPATE CUSTOMER EXPECTATIONS AND BETTER SERVE CLIENTS AS THEY DEMAND A MORE PERSONAL, IMMEDIATE EXPERIENCE. THE FUTURE OF WORK: FIRMS ARE THINKING CRITICALLY ABOUT THE FUTURE OF THE WORKPLACE, WITH MANY ALREADY IMPLEMENTING HYBRID OR REMOTE WORK ARRANGEMENTS FOR CERTAIN POPULATIONS. THERE ARE BENEFITS TO SUCH ARRANGEMENTS, INCLUDING THE ABILITY TO ATTRACT DIVERSE TALENT BY NOT BEING TIED TO A PARTICULAR LOCATION AND OFFERING GREATER FLEXIBILITY TO MANAGE WORK AND PERSONAL OBLIGATIONS. THE SECURITIES INDUSTRY OPERATES IN A HIGHLY REGULATED ENVIRONMENT WITH RULES GOVERNING THE REGISTRATION AND SUPERVISION OF OFFICE LOCATIONS. THOSE RULES ARE DECADES-OLD AND WERE BASED ON PHYSICAL OFFICE LOCATIONS. EVEN AS REGULATORS THEMSELVES HAVE ADAPTED SUCCESSFULLY TO REMOTE WORKING, THERE'S A HESITANCY AMONG SOME TO MODERNIZE THE REGULATORY REGIME TO ACCOMMODATE A REMOTE OR HYBRID WORKFORCE. SIFMA BELIEVES REGULATORS MUST COLLABORATE WITH THE INDUSTRY TO TRANSITION TO A "NEW NORMAL AND TO ADDRESS ANY CONCERNS. FIRMS OF ALL SIZES WERE ALREADY IN A YEARS-LONG PROCESS OF INVESTING IN AND UPGRADING THEIR TECHNOLOGICAL AND SUPERVISORY CAPABILITIES AND HAVE FOUND THAT THOSE INVESTMENTS ALSO SUPPORT A REMOTE WORKFORCE WHILE COMPLYING WITH REGULATIONS DESIGNED FOR INVESTOR PROTECTION. THE INDUSTRY CONTINUES TO SEE THE VALUE IN IN-PERSON INTERACTIONS, ESPECIALLY THE CAMARADERIE AND CULTURE-BUILDING IT OFFERS; HOWEVER, SIFMA BELIEVES THAT DIFFERENT MODELS CAN COEXIST. THE INDUSTRY SHOULD BE ABLE TO ADAPT TO THE NEEDS OF CUSTOMERS AND THE WORKFORCE, HAVE REGULATIONS THAT REFLECT THE WORKPLACE OF THE FUTURE, AND HAVE FACE-TO-FACE REQUIREMENTS AS THE BUSINESS WANTS AND THE RISKS WARRANT. ENHANCING MONEY MARKET FUND RESILIENCE: FOLLOWING PERIODS OF MARKET VOLATILITY AND LIQUIDITY ISSUES SEEN IN 2020, EFFORTS CONTINUE TO ENSURE MONEY MARKET FUNDS (MMF) ARE RESILIENT TO CREDIT AND LIQUIDITY STRESSES. REGULATORS SEEM TO BE PARTICULARLY CONCERNED, THAT MMFS COULD HAVE REDEMPTION CONCERNS ISSUES, FINDING THEMSELVES UNABLE TO SELL ASSETS DURING STRESSED SITUATIONS. SIFMA'S ASSET MANAGEMENT GROUP CONTINUES TO ENGAGE WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION, THE FINANCIAL STABILITY BOARD, AND OTHER GLOBAL REGULATORS AS POTENTIAL RULEMAKINGS DEVELOP. AMONG THE PROPOSALS UNDER CONSIDERATION, SIFMA AMG MEMBERS AND MANY OTHER MARKET PARTICIPANTS HAVE ARGUED THAT DELINKING LIQUIDITY FROM FEES AND GATES WOULD BE HELPFUL IN COUNTERACTING ANY POTENTIAL LIQUIDITY CONCERNS; MOST OF THE OTHER PROPOSALS UNDER CONSIDERATION SHOULD BE FURTHER STUDIED AS THEY COULD HARM THE FUNCTIONING OF THESE VITAL MARKETS WITHOUT ACTUALLY IMPROVING THEIR RESILIENCY. DEMONSTRATING ANTITRUST NEEDS FOR AGGREGATION RULES: THE HART-SCOTT-RODINO ANTITRUST IMPROVEMENTS ACT OF 1976 REQUIRES COMPANIES TO FILE PRE-MERGER NOTIFICATIONS WITH THE FEDERAL TRADE COMMISSION AND THE ANTITRUST DIVISION OF THE JUSTICE DEPARTMENT FOR CERTAIN ACQUISITIONS. UNDER CURRENT LAW, EACH INDIVIDUAL MUTUAL FUND THAT OWNED MORE THAN 5% HAD TO FILE. THE FTC AND DOJ HAVE PUBLISHED PROPOSED CHANGES TO THE RULES AND INTERPRETATIONS IMPLEMENTING THE ACT; IF THE PROPOSALS ARE IMPLEMENTED, ASSET MANAGERS WILL BE REQUIRED TO AGGREGATE POSITIONS IN AN ISSUER ACROSS ALL FUNDS WHEN ASSESSING FILING THRESHOLDS. SIFMA'S ASSET MANAGEMENT GROUP HAS OUTLINED SIGNIFICANT CONCERNS WITH THE PROPOSED AGGREGATION REQUIREMENT AND THE INCORPORATION OF THE ACADEMIC THEORY OF COMMON OWNERSHIP, WHICH ASSERTS THAT THE MERE OWNERSHIP OF SHARES OF COMPETITOR COMPANIES HARMS COMPETITION. THE PROPOSED AGGREGATION RULE WOULD SIGNIFICANTLY INCREASE THE NUMBER OF FILINGS WITHIN THE ASSET MANAGEMENT INDUSTRY. THE FILING FEES AND DELAY ON INVESTORS' ACQUISITIONS OF SECURITIES WOULD IMPAIR MARKET EFFICIENCY AND NEEDLESSLY INCREASE COSTS FOR RETAIL INVESTORS, ESPECIALLY SAVERS AND RETIREES WHOSE INVESTMENTS ARE THEIR MAIN SOURCE OF INCOME. ENHANCING TRANSPARENCY IN FIXED INCOME MARKETS: FIXED INCOME MARKETS ARE AN INTEGRAL COMPONENT TO ECONOMIC GROWTH, PROVIDING EFFICIENT, LONG TERM AND COST-EFFECTIVE FUNDING. THEY ARE ALSO ONE OF THE MOST HEAVILY REGULATED AREAS OF THE U.S. CAPITAL MARKETS. TWO REGULATORY PROPOSALS OF NOTE INCLUDE THOSE RELATED TO RULE 15C2-11 AND REGULATION ATS. THE U.S. SECURITIES AND EXCHANGE COMMISSION IS CONSIDERING APPLYING RULE 15C2-11 TO THE FIXED INCOME MARKETS. THE RULE, WHICH WAS IMPLEMENTED IN 1971, AMENDED IN 1975, 1991, AND AGAIN IN 2020, IS AND ALWAYS HAS BEEN TARGETED AT PROTECTING RETAIL INVESTORS FROM OTC EQUITY MARKET FRAUD AND HAS NEVER BEEN ENFORCED IN FIXED INCOME MARKETS. SIFMA MEMBERS, INCLUDING OUR INVESTOR MEMBERS WHOM THE RULE IS NOMINALLY PURPORTED TO PROTECT, STRONGLY BELIEVE THIS RULE IS NOT NEEDED IN OR APPROPRIATE FOR FIXED INCOME MARKETS. NONETHELESS, IF THE COMMISSION DESIRES TO APPLY THIS RULE TO SOME PORTION OF THE FIXED INCOME MARKETS, SIFMA MEMBERS BELIEVE THAT THE RULE SHOULD NOT APPLY TO FIXED INCOME MARKETS WITHOUT THE OPPORTUNITY FOR THE PUBLIC TO RECEIVE NOTICE AND PROVIDE COMMENT ON THE PROPOSED APPLICATION OF IT, GIVEN THE MATERIAL POLICY CHANGE ITS APPLICATION WOULD REPRESENT, AND SHOULD INCLUDE A SIGNIFICANT REDUCTION IN THE PROPOSED SCOPE OF COVERAGE OF THE RULE. SIFMA HAS REQUESTED RELIEF FROM THE SEC AND CONTINUES TO DISCUSS THIS IMPORTANT RULE WITH THEM. FAILURE TO TAKE THESE STEPS WOULD THREATEN THE CONTINUED EXPANSION OF LIQUIDITY AND TRANSPARENCY IN THESE MARKETS AND MAY INCREASE TRANSACTION COSTS, HARMING INVESTORS. THE U.S. SECURITIES AND EXCHANGE COMMISSION HAS ALSO PROPOSED AMENDMENTS TO REGULATION ATS UNDER THE SECURITIES AND EXCHANGE ACT OF 1934 AS THEY RELATE TO GOVERNMENT SECURITIES ALTERNATIVE TRADING SYSTEMS (ATS). SIFMA GENERALLY SUPPORTS INCREASED OPERATIONAL TRANSPARENCY RELATED TO THE BASIC RULES OF OPERATION OF FIXED INCOME AND GOVERNMENT SECURITIES ATS'S. THERE IS VALUE IN OPERATIONAL TRANSPARENCY RELATED TO THE BASIC RULES OF OPERATION OF THE VENUE, THE ABILITY OF PRIORITY OR PREFERENTIAL TREATMENT (IF ANY) FOR CERTAIN DESKS OR CLIENTS AND INFORMATION ON RISK CONTROLS. AMONG OTHER THINGS, MORE OPERATIONAL TRANSPARENCY WOULD AID INVESTORS IN CONDUCTING ANALYSIS OF EXECUTIONS. SIFMA SUPPORTS TAILORING FORM ATS DISCLOSURES IN A MANNER THAT ADDRESSES THE UNIQUE CHARACTERISTICS OF THE FIXED INCOME AND OTHER MARKETPLACES TO BEST SERVE INVESTORS. FINANCING INFRASTRUCTURE FOR STATES AND MUNICIPALITIES: THERE IS A CLEAR PRESSING NEED TO INVEST IN OUR NATION'S INFRASTRUCTURE. MUNICIPAL BONDS FINANCE THE BRIDGES, ROADS, SCHOOLS AND HOSPITALS OUR COMMUNITIES RELY ON. WE HAVE AN INFRASTRUCTURE SPENDING SHORTFALL AND A CRITICAL NEED TO ADDRESS IT. FURTHER, THERE IS A DIFFERENCE BETWEEN FUNDING AND FINANCING EFFORTS. SIFMA'S PRIORITIES IN THIS SPACE ARE EFFECTIVE FINANCING TOOLS WITH THAT HAVE BEEN USED BY OVER 50,000 STATE AND LOCAL GOVERNMENTS FOR KEY INFRASTRUCTURE PROJECTS. MUNICIPAL FINANCE TOOLS, SUCH AS TAX-EXEMPT ADVANCE REFUNDINGS, CAN EASE THE BURDEN ON THE AMERICAN TAXPAYER THROUGH LOWER BORROWING COSTS WHILE ALSO BOLSTERING INVESTMENT IN CRITICAL PUBLIC NEEDS, ENHANCING THE QUALITY OF LIFE OF ALL AMERICANS. DIRECT PAY BONDS AND UPDATING SMALL ISSUER RULES WILL ATTRACT MORE PRIVATE CAPITAL TO STATE AND LOCAL GOVERNMENT PROJECTS, AND, COMBINED WITH ADVANCE REFUNDINGS, WILL SERVE AS CRITICAL INFRASTRUCTURE FUNDING TOOLS. IT IS A MISSED OPPORTUNITY TO NOT INCLUDE MUNICIPAL BOND PROVISIONS IN THE BUILD BACK BETTER RECONCILIATION BILL. STATE AND LOCAL GOVERNMENTS, UNLIKE VIRTUALLY EVERYONE ELSE IN AMERICA, ARE UNABLE TO TAKE FULL ADVANTAGE OF HISTORICALLY LOW INTEREST RATES THROUGH ADVANCE REFUNDINGS AND GENERATE CASHFLOW TO REINVEST IN THEIR COMMUNITIES. SIFMA AND ITS MEMBER FIRMS SUPPORT THE PRESERVATION OF THE TAX EXEMPTION FOR MUNICIPAL BONDS AS WELL AS FOUR MAIN INITIATIVES THAT WOULD HELP STATE AND LOCAL GOVERNMENTS FINANCE IMPORTANT INFRASTRUCTURE PROJECTS WHILE ALSO SAVING TAXPAYER DOLLARS: |
| FORM 990, PART III, LINE 4B | (1) SECURE THE PASSAGE OF LEGISLATION PERMITTING ISSUERS TO ADVANCE REFUND THEIR MUNICIPAL DEBT ON A TAX-EXEMPT MUNICIPAL BASIS; (2) AUTHORIZE A NEW DIRECT PAYMENT BOND PROGRAM ON A PERMANENT BASIS; (3) EXPAND THE VOLUME CAP AND USES FOR PRIVATE ACTIVITY BONDS (PABS); AND (4) INCREASE THE ANNUAL LIMIT ON THE AMOUNT OF TAX-EXEMPT OBLIGATIONS THAT MAY BE ISSUED TO QUALIFY FOR THE SMALL ISSUER EXCEPTION TO THE TAX-EXEMPT INTEREST EXPENSE ALLOCATION RULES. HELPING BUSINESSES AND INVESTORS MANAGE RISK: DERIVATIVES ARE AN IMPORTANT TOOL THAT BUSINESSES AND INVESTORS USE TO MANAGE RISK EXPOSURE. TITLE VII OF THE DODD FRANK ACT ESTABLISHED A BROAD NEW REGULATORY REGIME FOR OVER-THE-COUNTER (OTC) DERIVATIVES, OR SWAPS, WHICH IS PROFOUNDLY AFFECTING THE FINANCIAL MARKETS AND MARKET PARTICIPANTS. SIFMA BELIEVES THAT THE DODD-FRANK ACT TOOK SEVERAL IMPORTANT STEPS TOWARDS IMPROVING OVERSIGHT AND TRANSPARENCY IN THE SWAPS MARKETS AND SUPPORTS THE IMPLEMENTATION OF APPROPRIATE REGULATIONS THAT DO NOT CREATE UNDUE COSTS OR UNDULY LIMIT THE AVAILABILITY OF THESE VALUABLE RISK MANAGEMENT TOOLS. IN OCTOBER 2021, AN IMPORTANT STEP WAS ACHIEVED WHEN THE SEC'S SECURITY-BASED SWAP DEALER (SBSD) REGIME WENT LIVE AND THE FIRST SBSD REGISTRATIONS WERE REPORTED SOON THEREAFTER. SIFMA WILL CONTINUE TO ENGAGE CLOSELY WITH THE SEC AS IT WORKS TO COMPLETE TITLE VII RULEMAKING IN 2022. LOOKING FORWARD, POLICYMAKERS SHOULD CONTINUE TO HARMONIZE REGULATIONS BETWEEN THE SEC AND CFTC; AVOID OVERLY BROAD APPLICATION OF TITLE VII IN CROSS-BORDER SITUATIONS, INCLUDING EXPANDING THE AVAILABILITY OF BILATERAL REGULATORY RECOGNITION (SUBSTITUTED COMPLIANCE); AND CONTINUOUSLY REVIEW AND EVALUATE THE IMPACT OF REGULATIONS ON THE SWAP MARKETS AND MARKET PARTICIPANTS, INCLUDING END USERS SUCH AS ASSET MANAGERS AND THEIR CLIENTS. PROTECTING DATA & PRIVACY: PERSONAL FINANCIAL INFORMATION IS INVALUABLE AND THE FINANCIAL INDUSTRY IS COMMITTED TO ENSURING THE SAFETY OF THE CLIENTS WE SERVE AT EVERY TURN. SIFMA BELIEVES A FEDERAL PRIVACY AND DATA BREACH STANDARD IS NECESSARY TO BEST PROTECT THE PERSONAL FINANCIAL DATA OF ALL AMERICANS. MANY OF OUR MEMBERS FUNCTION REGIONALLY, NATIONALLY, AND GLOBALLY, AND THE CURRENT PATCHWORK OF CONFLICTING STATE AND FEDERAL LAWS AND REGULATIONS FURTHER ADDS TO THE CONFUSION AND INEFFICIENCY. ADOPTING A FEDERAL PREEMPTIVE STANDARD FOR PRIVACY AND DATA BREACH THAT TAKES INTO CONSIDERATION EXISTING POLICIES UNDER THE GRAMM-LEACH-BLILEY ACT WOULD GREATLY IMPROVE CUSTOMER PROTECTION BY MINIMIZING CONFUSION AND INEQUALITY. INVESTORS ARE INCREASINGLY LOOKING FOR TRANSPARENCY AS THEY DETERMINE HOW THEIR DATA IS BEING SHARED, USED AND PROTECTED. TO THAT END, SIFMA HAS PUBLISHED A SET OF INDUSTRY-WIDE PRINCIPLES, FOCUSING ON ACCESS; SECURITY AND RESPONSIBILITY; TRANSPARENCY AND PERMISSION; AND SCOPE OF ACCESS AND USE, FOR PROTECTING, SHARING AND AGGREGATING CUSTOMER FINANCIAL INFORMATION. SIFMA IS ALSO A FOUNDING MEMBER AND SERVE ON THE BOARD OF THE FINANCIAL DATA EXCHANGE (FDX), A NON-PROFIT STANDARDS BODY TASKED WITH DEVELOPING TECHNICAL SOLUTIONS FOR PERMISSIONED DATA TRANSFER BETWEEN FINANCIAL INSTITUTIONS AND TECHNOLOGY COMPANIES. IMPLEMENTING THE CONSOLIDATED AUDIT TRAIL: THE SEC ESTABLISHED THE CONSOLIDATED AUDIT TRAIL (THE CAT) TO ENABLE REGULATORS TO TRACK ALL ORDER AND TRADING ACTIVITY THROUGHOUT THE U.S. MARKETS FOR LISTED EQUITIES AND OPTIONS. WHILE OPERATED BY 25 SELF-REGULATORY ORGANIZATIONS (SROS) INCLUDING EQUITY AND OPTIONS EXCHANGES, UNDER THE SUPERVISION OF THE SEC, THE SECURITIES INDUSTRY HAS UNDERTAKEN EFFORTS TO BUILD AND STAND UP SYSTEMS NECESSARY TO COMPLY WITH THE CAT, WORKING DILIGENTLY THROUGH THE CORONAVIRUS PANDEMIC AND THE OPERATIONAL CHANGES, PRIORITIES AND DEMANDS IT BROUGHT. THE TRANSACTION DATABASE BECAME FULLY IMPLEMENTED IN DECEMBER 2021. THE SROS AND INDUSTRY ARE NOW WORKING ON THE DESIGN AND DEVELOPMENT OF THE CUSTOMER DATA BASE OR CAIS WHICH IS PROJECTED TO COME ONLINE IN MID-2022. THE DATA WITHIN CAT HAS BECOME A KEY REGULATORY TOOL AS EVIDENCED BY THE OCTOBER 2021 SEC STAFF REPORT ON JANUARY 2021 MARKET VOLATILITY WHICH USED CAT DATA TO RECREATE AND ANALYZE THE TRADING ACTIVITY. SEVERAL CRITICAL ISSUES REMAIN, MOST IMPORTANTLY DATA SECURITY AND FUNDING. SIFMA HAS CONTINUALLY VOICED CONCERNS ABOUT THE TYPE AND AMOUNT OF PERSONALLY IDENTIFIABLE INFORMATION (PII) DATA TO BE REPORTED TO AND MAINTAINED IN THE CAIS AND HAS REPEATEDLY OFFERED VIABLE ALTERNATIVES THAT WOULD SERVE THE SAME PURPOSE WITHOUT THE ATTENDANT DATA AND PRIVACY RISK TO INVESTORS. WE CONTINUE TO ENGAGE WITH THE SEC ON ITS AUGUST 2020 DATA SECURITY PROPOSAL WHICH WOULD, AMONG OTHER THINGS, PROHIBIT THE BULK DOWNLOADING OF CAT DATA AND WOULD STRICTLY AND CLEARLY PROHIBIT THE USE OF CAT DATA FOR ANY COMMERCIAL PURPOSE. WE CONTINUE TO ADVOCATE FOR A COLLABORATIVE, EQUITABLE AND TRANSPARENT FUNDING MODEL FOR THE CAT AND RECOMMENDED THAT THE COMMISSION DISAPPROVE THE PROPOSED MODEL SUBMITTED BY THE SROS. ENHANCING INVESTOR PROTECTION WHILE PRESERVING CHOICE: REGULATION BEST INTEREST FINALIZED BY THE SECURITIES AND EXCHANGE COMMISSION IN 2019 AND FULLY ENFORCEABLE AS OF JUNE 2020 SIGNIFICANTLY AND MEANINGFULLY UPGRADES THE EXISTING REGULATORY REGIME FOR BROKER-DEALERS, AND DIRECTLY ENHANCES INVESTOR PROTECTION. SIFMA ADVOCATED FOR THE CREATION OF SUCH A STANDARD FOR OVER A DECADE. THE RULE IS SPECIFIC WITH RESPECT TO THE OBLIGATIONS BROKERS OWE TO THEIR CLIENTS AND THE STEPS THEY MUST TAKE TO COMPLY, INCLUDING THE OBLIGATION TO ELIMINATE, DISCLOSE AND MITIGATE CERTAIN CONFLICTS OF INTEREST. IT IS ENHANCING INVESTOR PROTECTIONS, WHILE ALSO PRESERVING INVESTOR CHOICE AND ACCESS TO INVESTMENT ADVICE. REG BI SUBSTANTIALLY EXCEEDS THE PRECEDING FINRA SUITABILITY STANDARD AND IS BROADER IN SCOPE THAN THE NOW DEFUNCT DOL FIDUCIARY RULE. REG BI APPLIES ACROSS ALL CUSTOMER ACCOUNTS, NOT JUST RETIREMENT ACCOUNTS, AND WILL ALLOW THE SEC TO ENFORCE A COMMON STANDARD ACROSS THE INDUSTRY. PROTECTING SENIOR INVESTORS: BY 2030, SENIORS AGED 65 AND OVER WILL MAKE UP 18% OF THE NATION'S POPULATION. IN THE UNITED STATES, SENIORS LOSE AN ESTIMATED $2.9 BILLION EVERY YEAR IN CASES OF FINANCIAL EXPLOITATION REPORTED BY MEDIA OUTLETS, WHILE ONLY AN ESTIMATED 1 IN 44 CASES IS EVEN REPORTED TO AUTHORITIES. IT IS VITAL THAT WE ARE ABLE TO PROTECT OUR SENIOR INVESTORS FROM FINANCIAL EXPLOITATION AND THE DANGERS OF COGNITIVE DECLINE. SIFMA IS COMMITTED TO WORKING ACROSS THE FINANCIAL INDUSTRY TO PROTECT SENIOR INVESTORS AND CONTINUES TO SEEK NEW WAYS TO FIGHT AGAINST FINANCIAL EXPLOITATION OF OLDER AMERICANS. IN ADDITION TO OUR SENIOR INVESTOR PROTECTION TOOLKIT, WE WORK IN PARTNERSHIP WITH AARP TO DISTRIBUTE THE BANKSAFE TRAINING PROGRAM AND WITH ORGANIZATIONS INCLUDING THE WOMEN'S INSTITUTE FOR A SECURE RETIREMENT (WISER), THE NATIONAL ADULT PROTECTIVE SERVICES ASSOCIATION (NAPSA), FINRA AND MORE. PRESERVING THE INDEPENDENT CONTRACTOR MODEL: SIFMA SUPPORTS PRESERVATION OF THE INDEPENDENT CONTRACTOR STATUS IN THE FINANCIAL SERVICES INDUSTRY WHERE INDEPENDENT BROKER-DEALER AND INDEPENDENT FINANCIAL ADVISORS CAN PROVIDE SERVICES TO THEIR RETAIL AND INSTITUTIONAL CLIENTS. INDEPENDENT BROKER-DEALERS (IBDS) AND THE NEARLY 160,000 INDIVIDUALS THAT AFFILIATE WITH THEM AS INDEPENDENT FINANCIAL ADVISORS (IFAS) SERVE MILLIONS OF CLIENTS ACROSS THE U.S. BY PROVIDING INVESTMENT ADVICE AND EDUCATION. IFAS PROVIDE CRUCIAL ADVICE ON RETIREMENT PLANNING, EDUCATIONAL FUNDING, AND OTHER LIFE EVENTS RETAIL INVESTORS IN ADDITION TO OFFERING OTHER SERVICES AND PRODUCTS, SUCH AS INSURANCE AND TAX PLANNING, THAT ADDRESS THEIR CLIENTS' FINANCIAL WELL-BEING HOLISTICALLY. INDEPENDENT CONTRACTOR STATUS ALLOWS INDEPENDENT FINANCIAL ADVISORS TO OWN AND OPERATE THEIR OWN SMALL BUSINESS. INDEPENDENT FINANCIAL ADVISORS ALSO BENEFIT FROM A DECENTRALIZED BUSINESS STRUCTURE, WHICH EXPANDS THE ACCESSIBILITY OF FINANCIAL ADVICE AND PLANNING IN PARTS OF THE COUNTRY THAT WOULD OTHERWISE NOT BE SERVED. NOTABLY, INDEPENDENT FINANCIAL ADVISORS WORK IN A HIGHLY REGULATED INDUSTRY AND ARE REQUIRED BY SECURITIES LAWS TO ASSOCIATE WITH A BROKER-DEALER TO PROTECT INVESTORS. WE ENCOURAGE LAWMAKERS TO EXEMPT INDEPENDENT BROKER DEALERS AND INDEPENDENT FINANCIAL ADVISORS FROM ANY LEGISLATION, SUCH AS THE PROTECTING RIGHTS TO ORGANIZE ACT (PRO ACT), THAT WOULD PREVENT FINANCIAL SERVICES PROFESSIONALS FROM FREELY CHOOSING TO BE INDEPENDENT CONTRACTORS. |
| FORM 990, PART III, LINE 4B | PRUDENTIAL REGULATION OF CAPITAL MARKETS: PRUDENTIAL REGULATION REQUIRES FINANCIAL FIRMS TO CONTROL RISKS, HOLD ADEQUATE CAPITAL AND LIQUIDITY, AND HAVE IN PLACE WORKABLE RECOVERY AND RESOLUTION PLANS. IT IS ESSENTIAL THAT OUR REGULATORY REGIME ACCOUNTS FOR THE VITAL ROLE THE CAPITAL MARKETS PLAY IN PROVIDING CREDIT AND FINANCING THE REAL ECONOMY, PARTICULARLY AS REGULATORS CONSIDER THE IMPLEMENTATION OF ELEMENTS OF THE BASEL III CAPITAL PROPOSAL IN 2022, INCLUDING THE FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) AND CREDIT VALUATION ADJUSTMENT (CVA). IT IS VITAL THAT THOSE RULES SHOULD BE IMPLEMENTED IN A MANNER THAT DOES NOT OVERLY PENALIZE BANKS' CAPITAL MARKETS ACTIVITIES, WHICH IN TURN COULD REDUCE LIQUIDITY IN VITAL CORPORATE AND OTHER FUNDING MARKETS, THEREBY HURTING GROWTH IN THE REAL ECONOMY. SIFMA SUPPORTS APPROPRIATE REGULATION OF THE CAPITAL MARKETS AND THEIR PARTICIPANTS BY BOTH MARKET REGULATORS, WHO HAVE DECADES OF EXPERIENCE IN PROMULGATING RULES AND SUPERVISING THE MARKETPLACE, AS WELL AS PRUDENTIAL REGULATORS. U.S. PRUDENTIAL RULES GENERALLY IMPOSE SIGNIFICANTLY HIGHER CAPITAL AND LIQUIDITY COSTS ON BANKING ENTITIES WITH SIGNIFICANT CAPITAL MARKETS OPERATIONS. THIS HAS INCREASED COSTS TO FINANCIAL FIRMS AND THE ECONOMY AS A WHOLE AND REDUCED MARKET DEPTH FOR A WIDE VARIETY OF CORPORATIONS AND OTHER END-USERS, PARTICULARLY DURING PERIODS OF ECONOMIC STRESS. THIS HAS ALSO HAD ANOTHER EFFECT: TRANSFORMING U.S. BANKING REGULATORS INTO THE MOST IMPACTFUL SUPERVISOR OF THE CAPITAL MARKETS SUPERSEDING THE OVERSIGHT ROLE TRADITIONALLY PLAYED BY THE SEC AND CFTC. THIS HAS CREATED DISTORTIONS IN THE CAPITAL AND LIQUIDITY REQUIREMENTS BETWEEN MARKET AND PRUDENTIAL REGULATORS AS WELL AS LESSENED THE EFFICIENCIES BY INCREASING COSTS TO END USERS. IT IS THUS CRUCIAL TO ALIGN AND ALLOW FOR MUTUAL RECOGNITION, TO THE EXTENT POSSIBLE, THE CAPITAL AND LIQUIDITY STANDARDS SET OUT BY THE U.S. BANKING REGULATORS AND THE MARKET REGULATORS. TAX POLICY TO SUPPORT GROWTH: TAXES IMPACT THE SAVINGS AND INVESTMENT DECISIONS OF INDIVIDUALS AND CORPORATIONS AND ARE A NECESSARY MEANS FOR FUNDING THE GOVERNMENT. SIFMA BELIEVES REASONABLE TAXATION AND ECONOMIC GROWTH ARE NOT MUTUALLY EXCLUSIVE AND ENCOURAGES POLICY MAKERS TO CONSIDER BOTH WHEN CONTEMPLATING CHANGES TO THE TAX CODE. MANY OF SIFMA'S MEMBERS ARE GLOBAL TAXPAYERS AS WELL, THEREFORE INTERNATIONAL STANDARDS FOR RAISING REVENUE SHOULD CONSIDER THE HIGHLY REGULATED NATURE OF THE FINANCIAL SERVICES INDUSTRY. SIFMA'S MEMBER FIRMS ARE WILLING AND PREPARED TO HELP POLICYMAKERS WADE THROUGH THE NUANCES AND GOALS OF THEIR RESPECTIVE TAX POLICY. SIFMA BELIEVES TAXES IMPACT SAVINGS AND INVESTMENTS FOR BOTH INDIVIDUALS AND BUSINESSES, BUT REMAIN NECESSARY FOR GOVERNMENT PROGRAMS AND SUPPORT FOR DOMESTIC ECONOMIC GROWTH. WE REMAIN FOCUSED ON INTERNATIONAL TAX, CAPITAL GAINS AND DIVIDENDS AS WELL AS PROTECTING INVESTORS AND SAVERS FROM TAXES THAT COULD HURT THEIR FUTURE SAVINGS. FOSTERING DIVERSITY, EQUITY & INCLUSION: SIFMA ADVOCATES FOR A DIVERSE AND INCLUSIVE FINANCIAL INDUSTRY. TOGETHER WITH OUR MEMBERS, WE STRIVE TO PROVIDE FIRMS ACROSS THE FINANCIAL SERVICES INDUSTRY WITH THE RESOURCES NEEDED TO ACHIEVE, EXPAND AND PROMOTE WORKFORCE, CLIENT, AND SUPPLIER DIVERSITY AND INCLUSION. |
| FORM 990, PART III, LINE 4C | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS CONFERENCES AND SEMINARS: SIFMA CONFERENCES, EVENTS AND WEBINARS FOSTER MEANINGFUL CONVERSATIONS ABOUT THE CAPITAL MARKETS AND PROVIDE VALUABLE PROFESSIONAL DEVELOPMENT OPPORTUNITIES. SIFMA ANNUAL MEETING: FOR NEARLY 50 YEARS, SIFMA'S ANNUAL MEETING HAS BEEN THE PLACE WHERE THE CAPITAL MARKETS MEET. SIFMA GATHERS THE MOST INFLUENTIAL VOICES SHAPING TODAY'S CAPITAL MARKETS TO CHALLENGES AND GAIN INSIGHTS INTO OPPORTUNITIES AHEAD. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR: SIFMA'S COMPLIANCE & LEGAL SEMINAR IS THE PREEMINENT MEETING PLACE FOR COMPLIANCE AND LEGAL PROFESSIONALS FROM ACROSS THE FINANCIAL SERVICES INDUSTRY. THROUGHOUT THE PROGRAM, PARTICIPANTS HEAR DIRECTLY FROM INDUSTRY LEADERS AND REGULATORS ON THE LATEST DEVELOPMENTS AND TRENDS AND BUILD PROFESSIONAL RELATIONSHIPS TO COLLABORATE BETTER. OPERATIONS CONFERENCE & EXHIBITION: SIFMA'S OPERATIONS CONFERENCE & EXHIBITION GATHERS OPERATIONS, TECHNOLOGY AND REGULATORY LEADERS FROM ACROSS THE SECURITIES INDUSTRY TO DISCUSS THE MOST CRITICAL PRIORITIES. WITH THE INDUSTRY CONTINUING TO EVOLVE IN RESPONSE TO POLICY, RISK, TECHNOLOGY AND REGULATORY CHANGES, OPS DELVES INTO THE DYNAMIC AND COMPLEX ENVIRONMENT THAT IS RESHAPING OPERATIONS, THE CUSTOMER EXPERIENCE AND MARKET REQUIREMENTS. THE SECURITIES INDUSTRY INSTITUTE: THE SECURITIES INDUSTRY INSTITUTE (SII) IS THE PREMIER EXECUTIVE DEVELOPMENT PROGRAM FOR SECURITIES INDUSTRY PROFESSIONALS, HOSTED BY SIFMA AND WHARTON. FOR 70 YEARS, SIFMA AND THE WHARTON SCHOOL HAVE PARTNERED TO DEVELOP THE INDUSTRY'S HIGH-POTENTIAL RISING LEADERS. OVER THREE CONSECUTIVE YEARS SII PARTICIPANTS DEVELOP LEADERSHIP AND MANAGERIAL SKILLS AND ENHANCE INVESTMENT AND INDUSTRY KNOWLEDGE. SII'S COST-EFFECTIVE TALENT DEVELOPMENT APPROACH DELIVERS ACTIONABLE KNOWLEDGE THAT IS IMPLEMENTABLE TODAY: THE MISSION OF THE INSTITUTE IS TO EQUIP EACH PARTICIPANT WITH PRACTICAL INFORMATION, IDEAS, AND ANSWERS DIRECTLY APPLICABLE TO THEIR PRESENT AND FUTURE RESPONSIBILITIES. ITS CUSTOMIZED CURRICULUM IS REDESIGNED EACH YEAR TO REFLECT THE NEEDS OF AN EVER-CHANGING INDUSTRY LANDSCAPE. |
| FORM 990, PART VI, SECTION A, LINE 6 | MEMBERS SIFMA IS A MEMBERSHIP ORGANIZATION WITH THE FOLLOWING CLASSES OF MEMBERSHIP: BROKER-DEALER MEMBERS AND ASSET MANAGER MEMBERS EACH BROKER-DEALER MEMBER AND ASSET MANAGER MEMBER SHALL BE ENTITLED TO VOTE WITH RESPECT TO THE ELECTION OF DIRECTORS AND OTHER MATTERS AS MAY BE SUBMITTED AT ANY ANNUAL OR OTHER MEETING OF MEMBERS ENTITLED TO VOTE. ASSOCIATE MEMBERS ASSOCIATE MEMBERS SHALL NOT BE ENTITLED TO VOTE WITH RESPECT TO THE ELECTION OF DIRECTORS AND OTHER MATTERS AS MAY BE SUBMITTED AT ANY ANNUAL OR OTHER MEETING OF MEMBERS ENTITLED TO VOTE, AND SHALL NOT BE ELIGIBLE TO SERVE AS DIRECTORS OF THE ASSOCIATION. |
| FORM 990, PART VI, SECTION A, LINE 7A | SIMFA IS A MEMBERSHIP ORGANIZATION AND MEMBERS HAVE THE FOLLOWING POWERS WITH RESPECT TO THE GOVERNING BODY: BROKER-DEALER MEMBERS AND ASSET MANAGER MEMBERS: EACH BROKER-DEALER MEMBER AND ASSET MANAGER MEMBER SHALL BE ENTITLED TO VOTE WITH RESPECT TO THE ELECTION OF DIRECTORS AND OTHER MATTERS AS MAY BE SUBMITTED AT ANY ANNUAL OR OTHER MEETING OF MEMBERS ENTITLED TO VOTE. ASSOCIATE MEMBERS: ASSOCIATE MEMBERS SHALL NOT BE ENTITLED TO VOTE WITH RESPECT TO THE ELECTION OF DIRECTORS AND OTHER MATTERS AS MAY BE SUBMITTED AT ANY ANNUAL OR OTHER MEETING OF MEMBERS ENTITLED TO VOTE, AND SHALL NOT BE ELIGIBLE TO SERVE AS DIRECTORS OF THE ASSOCIATION. |
| FORM 990, PART VI, SECTION B, LINE 11B | FORM 990 REVIEW PROCESS: THE ACCOUNTING DEPARTMENT OF THE ORGANIZATION PREPARES THE FORM 990 BASED ON AUDITED FINANCIAL INFORMATION. THE DRAFT FORM 990 IS THEN REVIEWED BY MANAGEMENT AND AN EXTERNAL INDEPENDENT ACCOUNTING FIRM. THE AUDIT AND FINANCE COMMITTEE WILL REVIEW THE FINAL DRAFT SIGNED OFF BY THE EXTERNAL INDEPENDENT TAX ACCOUNTANT. THIS REVIEW WILL BE NOTED AS AN AGENDA ITEM AT AN AUDIT AND FINANCE COMMITTEE MEETING AND WILL BE DULY NOTED IN THE MINUTES. THE FORM 990 WILL BE PROVIDED TO ALL VOTING MEMBERS OF THE BOARD OF TRUSTEES PRIOR TO SUBMISSION TO THE IRS. |
| FORM 990, PART VI, SECTION B, LINE 12C | CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT: ANY EMPLOYEE IN A POSITION WHERE HIS OR HER OBJECTIVITY MAY BE QUESTIONED BECAUSE OF AN INDIVIDUAL INTEREST OR FAMILY OR PERSONAL RELATIONSHIP IS REQUIRED TO NOTIFY THE GENERAL COUNSEL. SIMILARLY, ANY EMPLOYEE AWARE OF ANY TRANSACTION OR RELATIONSHIP THAT COULD REASONABLY BE EXPECTED TO GIVE RISE TO A PERSONAL CONFLICT OF INTEREST IS REQUIRED TO DISCUSS THE MATTER PROMPTLY WITH THE GENERAL COUNSEL. IN ADDITION, ONCE EVERY YEAR, DIRECTORS, OFFICERS, KEY EMPLOYEES, AND ALL THE EMPLOYEES OF SIFMA ARE REQUIRED TO REVIEW A COPY OF THE CONFLICT OF INTEREST POLICY AND TO ACKNOWLEDGE IN WRITING THAT HE OR SHE IS COMPLIANT. |
| FORM 990, PART VI, SECTION B, LINE 15 | PROCESS FOR DETERMINING COMPENSATION: THE EXECUTIVE COMMITTEE AND THE BOARD ACTING AS COMPENSATION COMMITTEE HIRE CONSULTANTS TO REVIEW COMPARABLE PACKAGES FOR ANY NEW INCOMING CEO AND OFFICERS. THE CONSULTANT PRESENTS DATA FOR COMPARABLE POSITIONS BOTH LOCALLY AND NATIONALLY AND THE BOARD'S EXECUTIVE COMMITTEE MAKES THE FINAL DECISION FOR THE SALARY PACKAGE. CURRENTLY, THE CEO AND COO HAVE EMPLOYMENT CONTRACTS WHICH WERE APPROVED BY THE EXECUTIVE COMMITTEE AND THE BOARD, GOVERNING ANNUAL SALARY INCREASE AND ANY BONUS PAYMENTS. FOR THE REMAINING SENIOR OFFICERS, THE ANNUAL SALARY INCREASE AND BONUS PAYMENTS ARE DETERMINED BY THE ANNUAL EVALUATION PROCESS WHICH MUST BE APPROVED BY THE BOARD'S COMPENSATION COMMITTEE. |
| FORM 990, PART VI, SECTION C, LINE 19 | AVAILABILITY OF DOCUMENTS ANY REQUEST FOR GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS WILL BE PROVIDED UPON REQUEST AT MANAGEMENT'S DISCRETION. |
| FORM 990, PART XI, LINE 9: | POST-RETIREMENT RELATED CHANGES OTHER THAN NET PERIODIC POST RETIREMENT BENEFIT COST -296,345. |